EPA’s Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19
This memorandum/interim guidance supplements the “Office of Land and Emergency Management Considerations and Posture for COVID-19 Pandemic” document dated March 19, 2020, and provides additional criteria to be considered for emergency response, Superfund removal/remedial/federal facilities, RCRA corrective action, and leaking underground storage tank (LUST) cleanups when determining whether site field work should continue or be suspended.
The EPA also indicates in the memorandum that it continues to evaluate and make decisions about continuing on-site activities on a case-by-case basis consistent with the following priorities:
- Protecting the health and safety of the public, as well as maintaining the health and safety of EPA staff and cleanup partners, is the Agency’s highest priority. Integral to the protection of health and safety is the adherence to any federal, state, tribal, or local health declarations and restrictions, to the extent possible.
- Maintaining EPA’s ability to prevent and respond to environmental emergencies, or in any situation necessary to protect public health and welfare and the environment, is also a critical priority for the Agency.
As with the enforcement interim guidance, protection of drinking water is a priority in these decisions as well.
Decisions to be made on continuing, reducing, or pausing field work are to be made on a case-by-case basis and in consultation with other EPA offices, as appropriate. This same approach will apply to decisions based on requests from outside parties (e.g., states, tribes, local governments, other federal agencies, PRPs, property owners, etc.) for extensions or delays in performance.