Technical Support Project for Cleaning Up Contaminated Sites - Ground Water Forum Document Review Procedures

EPA established the Technical Support Project (TSP) in 1987 to provide technical assistance to regional Remedial Project Managers, corrective action Staff, and On-Scene Coordinators. TSP consists of a network of regional forums and specialized technical support centers located EPA laboratories, and EPA's Environmental Response Team. The objectives of the TSP are to share information and best practices with other EPA programs and other federal agencies. For more information on the TSP, please visit Technical Support Project page. The following page contains the document review procedures of the TSP Ground Water Forum as adopted in July 2005:

DOCUMENT REVIEW PROCEDURES

  1. Any request for the Ground Water Forum (GWF or the forum) to review and provide comments on a document is submitted to the co-chairs.  The co-chairs determine the following details of the request from the requestor: the purpose of the document, intended audience of the document, the scope of review being requested, the deadline for completion of the review and if the deadline is flexible or hard, planned next steps of the requestor, and if the requestor will be providing a response to forum comments. The co-chairs in consultation with the forum determine the appropriateness of the GWF providing the requested document review.  The nature and scope of the review and the timeline to complete the review are established in consultation with the forum.  When appropriate, the co-chairs will contact the co-chairs of other TSP forums to invite participation in the review.
  2. The co-chairs ask via conference call, email or at a meeting for volunteers to review the document and for one person to chair the review workgroup.  To ensure that all GWF members have the opportunity to participate and lead, any solicitation during a conference call or meeting is followed up by an email solicitation to all GWF members.  The co-chairs review the list of workgroup volunteers and confirm the workgroup chair and members.  If there are not at least three regional workgroup members ( i.e. a quorum), the forum will not provide a review.  The co-chairs ensure that the workgroup chair is familiar with review procedures.
  3. The workgroup chair distributes the document for review to the other reviewers with a list of all workgroup members, explains the nature and scope of the review, and sets a deadline for comments to be submitted to him or her.  Workgroup members confirm their commitment to complete the review.  Upon receipt of the list of members, the workgroup reviews any potential conflicts of interest among its members.  If the workgroup decides that a conflict of interest exists, then the workgroup determines what action to take.  If there is not consensus within the workgroup (the person with the perceived conflict of interest does not participate in the vote) then the issue is sent to the entire forum for  dispute resolution as soon as possible (generally within one week). The workgroup chair informs the co-chairs of the review schedule and confirms that there is a quorum of workgroup members.  The co-chairs or workgroup chair informs the review requestor of the review schedule (or decision not to provide the review) nd the point of contact (i.e. workgroup chair).
  4. Workgroup members submit comments to the workgroup chair by the established deadline.  Written comments are submitted to the workgroup chair as emails that cc all members of the workgroup.  Written comments provide sufficient explanation for the reader to determine how the commenter’s position was achieved and include (as appropriate) any references for sources of information.
  5. The workgroup chair consolidates the comments.  The consolidation of comments entails putting the comments in similar format and order, eliminating redundant comments, and if the comments from different reviewers are conflicting, resolving the conflict.  If there are conflicting comments, the workgroup chair includes the conflicting comments in the consolidated comments, identifies the conflicts and submits them to the workgroup with a proposed plan of approach.  Conflicts should be resolved as quickly as possible.  The resolution is typically done by discussions with the authors of the conflicting comments.  If this action does not resolve the issue(s), a conference call with all of the review workgroup is held to resolve the opposing opinions.  A workgroup member may request a conference call with the entire workgroup to discuss the issues.  
  6. The draft consolidated comments are sent by the workgroup chair to the review workgroup for concurrence.  Any objection to the draft comments must be made to the workgroup chair in writing (including rationale for objections and proposed alternate wording) within the timeframe designated by the workgroup chair.  The workgroup chair will attempt to resolve any objections within the workgroup.
  7. If the workgroup chair determines that there is not consensus within the workgroup and objections to or conflicts between comments cannot be resolved within the workgroup, then the opposing views are brought to the forum membership for resolution (following the procedures in Section V of the “By-Laws”).  The workgroup chair prepares a summary of the conflict, aggregating or dividing issues as needed.  The summary will include brief position statements on both sides of the issue items.   The workgroup chair sends the conflict summary to the forum co-chairs for distribution to the forum membership for vote by the regional members to resolve the dispute.   Consistent with Section V of the “By-Laws”, only regional forum members participate in the dispute resolution vote.
  8. Once objections or conflicts (if any) within the workgroup are resolved, the comments are sent by the workgroup chair to the GWF co-chairs for distribution to the forum as “draft final”.  Objections to the draft final comments from any forum member or participant must be made to the workgroup chair in writing (including rationale for objections and proposed alternate wording) within the brief timeframe designated by the workgroup chair.  The workgroup chair will attempt to resolve any objections with the workgroup.  If any objections from the forum cannot be resolved informally by the workgroup, the same dispute resolution process is followed as previously outlined.
  9. Once any objections are resolved, the comments are finalized, and the standard disclaimer is added, the comments are sent by the workgroup chair to the GWF co-chairs for transmittal of the forum comments to the requestor of the review.   The disclaimer is: Information and opinions contained in comments developed by the Ground Water Forum are technical in nature and represent the professional opinions of the participants. This information has not received formal EPA peer review and does not necessarily reflect the views of EPA or other participating organizations, and no official endorsement should be inferred.  The comments should not be construed to represent official EPA policy.  The information is not intended, nor can it be relied upon, to create any rights enforceable by any party in litigation with the United States or any other party. Use or mention of trade names does not constitute an endorsement or recommendation for use.
  10. If there is a response to comments, it is disseminated to the review workgroup for review. If the response in inadequate, the workgroup chair notifies the GWF co-chairs for further  potential action.
  11. Workgroup chair will maintain a record of the review process until the document under review is finalized and published.  This record should be sufficient to substantiate the review process and will include all submitted comments identified by originator, the consolidated comments, and any position statements prepared to support objections.