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Round 3-5b: PRP Performance of Risk Assessments

Reform Description
This initiative reaffirms EPA's commitment to authorize potentially responsible parties (PRPs) to perform risk assessments under the proper circumstances.

This initiative was instituted to:
  • Make the cleanup process more efficient;
  • Improve communication between EPA and PRPs;
  • Give PRPs a greater role in characterizing site risks;
  • Reduce EPA's oversight requirements; and
  • Decrease the time needed for conducting a remedial investigation and feasibility study (RI/FS).
In January 1996, EPA released a revised policy (see Documents below) on allowing PRPs to conduct risk assessments at most sites where they are also performing an RI/FS. The directive listed six criteria that the Regions are to consider when deciding whether or not to authorize PRPs to perform a risk assessment. The new policy also removed the previous requirement for the Regions to consult with Headquarters before authorizing a PRP to conduct the risk assessment.

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Reform Status
check mark Implementation of this reform is complete.

The Agency incorporated into the program lessons learned from this reform through the issuance of Revised Policy of Performance of Risk Assessment During Remedial Investigation/Feasibility Studies (RI/FS) by Potential Responsible Parties on January 26, 1996.

EPA plans to survey Regions for information about PRPs performing remedial investigation and feasibility studies, but not baseline risk assessments.

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As a result of this reform, EPA developed policy and guidance on allowing PRPs to conduct risk assessments.

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Stakeholder Comments
The following text appreared in "A Chemical Industry Perspective on EPA's Superfund Administrative Reforms," a report by the Chemical Maufacturers Association:

"[PRPs performing risk assessments] is a welcome development. EPA has over the years changed its mind about whether PRPs may perform risk assessments."

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Title: Revised Policy on Performance of Risk Assessment During Remedial Investigation/Feasibility Studies (RI/FS) by Potentially Responsible Parties
Date: January 26, 1996
Document #: OSWER 9340.1-02
Synopsis: This directive details EPA's revised policy of allowing PRPs to conduct risk assessments.

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