1. Cleaning Up After the Storm
You have heard that possession is nine tenths of the law? It also tends to be the case that perception is nine tenths of reality. For example, what I think you said is what you actually said, even if it isn’t. The overriding premise that we, the EPA AND LDEQ, worked to operate from is that we as regulators needed to convey ASBESTOS requirements, rules and regulations in a simple, easy to understand manner.

2. Communication Can You Hear Me Now? Cleaning Up After the Storm
WE CAN ALL AGREE THAT GOOD COMMUNICATION, FROM THE BIGGEST POINT TO THE SMALLEST POINT, IS VERY IMPORTANT. BUT, ANOTHER POINT WE ALL CAN ALSO AGREE ON -- I MAY THINK I HAVE COMMUNICATED WELL, WHEN WHAT I WANTED SOMEONE TO HEAR IS NOT WHAT THEY HEARD.

3. Does Everyone Understand?
Cleaning Up After the Storm
Does Everyone Understand?
HIGH
WIDE WIDE
DEEP
FOR REGULATORY COMPLIANCE, IT HAS BEEN IMPORTANT THAT POLICIES AND REQUIREMENTS BE TRANSMITTED THROUGHOUT THE ORGANIZATION THAT IMPLEMENTS THE POLICIES AND REQUIRMENTS. FROM THE TOP MANAGEMENT TO THE WORKER THAT HOLDS THE WETTING AGENT HOSE, AND TO EACH MEMBER OF THE CREW THAT IS ON THE SITE.

4. Coordination Coordination
Cleaning Up After the Storm
Who is on First
Coordination
Coordination Coordination
WHEN EVERYONE KNOWS THE POLICIES AND PROCEDURES, AND WHAT IS NECESSARY FOR REGULATORY COMPLIANCE, THE NEXT THING IS THE COORDINATION INVOLVED IN CARRYING THE POLICIES AND PROCEDURES OUT. IF THE EXCAVATOR OPERATOR AND THE WETTING AGENT HOSE OPERATOR ON AN ASBESTOS DEMOLITION SITE DON’T COORDINATE THEIR ACTIVITIES, VISIBLE EMISSIONS MAY OCCUR WHICH VIOLATE THE NESHAP/LESHAP.

5. How Do You Spell It? Cleaning Up After the Storm
COORDINATION ON A DEMOLITION SITE IS AN ONGOING PROCESS. EACH HAND MUST KNOW WHAT THE OTHER HAND IS DOING, OR MISTAKES ARE MORE LIKELY TO HAPPEN.

6. One Size Does Not Fit All
Cleaning Up After the Storm
One Size Does Not Fit All
DEMOLITION SITE CONDITIONS WILL VARY, NECESSITATING DIFFERENT APPROACHES AND TOOLS. ONE SIZE DOESN’T FIT ALL.
ON ONE PARTICULAR DEMOLITION SITE IN THE NINTH WARD, THE EXCAVATOR OPERATOR AND WETTING AGENT HOSE OPERATOR WERE HAVING DIFFICULTY COORDINATING TO KEEP THE WORK ADEQUATELY WET. THE SITE SUPERVISOR TOOK THE LABORER OFF THE WETTING AGENT HOSE AND GAVE THE WETTING JOB TO A CREW LEADER, WHO HAD THE AUTHORITY AND ‘WHERE-WITH-ALL’ TO MANAGE THE WORK EFFECTIVELY.

7. INFORMATION FLOW Cleaning Up After the Storm
ONE OF THE WORST THINGS THAT CAN HAPPEN TO IMPEDE COORDINATION AND COMMUNICATION IS WHEN INFORMATION ONLY FLOWS ONE WAY. WHEN A REGULATOR VISITS A SITE AND FINDS DEFICIENCIES, IF THE NATURE OF THE PROBLEM DOESN’T GET CONVEYED TO MANAGEMENT, THE SOURCE OF THE PROBLEMS MAY NEVER BE COMPLETELY DEALT WITH.

8. Delivering the Message
Cleaning Up After the Storm
Delivering the Message
Know Who To Talk To
Face-to-Face can Win the Race
Been There and Seen It
LDEQ SCHEDULED PERIODIC MEETINGS WITH THE UPPER MANAGEMENT OF THE PRIME CONTRACTORS DOING DEMOLITION WORK INVOLVING ASBESTOS. SO, WHEN A SITE VISIT WAS CONDUCTED AND DEFICIENCIES WERE FOUND, IF A FINDING OF VIOLATION WAS WRITTEN THAT THE SITE SUPERVISOR SIGNED, AND A COPY WAS THEN SENT TO THE COMPANY MANAGEMENT, EVERYONE FROM THE SITE WORKERS THROUGH THE SITE SUPERVISOR TO THE TOP MANAGEMENT WERE AWARE OF THE ISSUES. SO WHEN THE FACE-TO-FACE MEETINGS WITH UPPER MANAGEMENT OCCURRED, COMMUNICATION AND COORDINATION WERE FACILITATED, AND SOLUTIONS RESULTED. ALSO, THE LDEQ FOLKS THAT MET WITH MANAGEMENT WERE THE LDEQ REPRESENTATIVES THAT INSPECTED THE SITES.

9. Read the Regs? Are You Serious?
Cleaning Up After the Storm
Read the Regs? Are You Serious?
Horizontal AND Vertical Information Transfer -- Reach out to Everyone
Tools to get the Message HIGH, DEEP, & WIDE -- The Asbestos Matrix, LDEQ Website, Trainings
TO FACILITATE ‘HIGH, DEEP, AND WIDE’ INFORMATION TRANSFER, EPA AND LDEQ PUT TOGETHER A MATRIX WHICH STATED THE NESHAP/LESHAP ASBESTOS REQUIREMENTS IN SIMPLE, BASIC TERMS. CALLED THE LOUISIANA KATRINA/RITA NESHAP MATRIX , WHEN MADE AVAILABLE TO THE USACE, CONTRACTORS, LOCAL GOVERNMENTS, AND POSTED ON THE LDEQ WEBSITE, THE MATRIX EXPLAINED THE DETAILS OF THE REQUIREMENTS UNDER THE NAA IN TERMS EASIER TO UNDERSTAND THAN IF ONE WERE TO PICK UP A CFR.

10. FLEXIBILITY WITH NAA LTR
Cleaning Up After the Storm
The Asbestos Matrix
TYPE OF STRUCTURE
ACTIVITY
NESHAP
FLEXIBILITY WITH NAA LTR
UNSOUND STRUCTURE (structure subject to a governmental demolition order for which a thorough inspection is not possible)
inspection
Thorough inspection not required (due to structure being structurally unsound and in imminent danger of collapse). Structure is subject to a governmental demolition order.
1. Unsound structure definition expanded
To include homes that are structurally
unsound or moved off their foundation
but not necessarily in danger of imminent
collapse. (2/3/06-2/3/07)
2. Government Issued demolition orders
for groups of covered residences (e.g. a
block, sub-division, or other appropriate
Geographic area) the same as an
order based on individual determination.
(2/3/06 2/3/07)
3. Unsound structures definition
expanded to include homes that are
uninhabitable for other environmental
reasons. (2/24/06-2/3/07)
AN EXAMPLE OF PART OF THE MATRIX IN THE ASBESTOS SECTION OF THE LDEQ WEBSITE.

11. What About the Bridge? Cleaning Up After the Storm
IT OFTEN HAPPENS THAT THE MOST IMPORTANT PART OF A MESSAGE GETS OVERSHADOWED BY EXTRANEOUS INFORMATION.

12. Major in the Minors?, or Minor in the Majors?
Cleaning Up After the Storm
What’s Your Plan, Stan?
Major in the Minors?, or Minor in the Majors?
The Biggies, The Basics, & The Details
WHEN PUTTING TOGETHER A COMMUNICATION PLAN, IT IS CRUCIAL THAT THE IMPORTANT PART OF THE MESSAGE STANDS OUT. ACCENTUATE THE BIG ISSUES, STICK TO THE BASICS, AND WATCH THE DETAILS AS THE PLAN IS CARRIED OUT. FOR EXAMPLE; A LOT OF PEOPLE WERE ASKING HOW TO HANDLE ASBESTOS ISSUES, AND GETTING MIRED IN DETAILS. LDEQ AND EPA WANTED TO CONVEY A CONSISTANT, SIMPLER, UNDERSTANDABLE MESSAGE. DOCUMENTS WERE CREATED TO IMPART THE BASIC INFORMATION (MATRIX, INSPECTION POLICY, WASTE HANDLING POLICY, ETC.). TRAININGS WERE HELD TO SHOW AND EXPLAIN THE DOCUMENTS. INSPECTIONS AND SITE VISITS WERE CONDUCTED TO MONITOR COMPLIANCE WITH THE BIG ISSUES. REPORTS WERE CREATED AND FED INTO THE COMMUNICATION STREAM TO IMPART FINDINGS AND PROMOTE COMPLIANCE, AND DEAL WITH INDIVIDUAL DETAILS ON PARTICULAR TYPES OF JOBS.

13. Give Refreshers on the Basics Monitor for the Details
Cleaning Up After the Storm
Plan Structure
Reiterate the Biggies
Give Refreshers on the Basics
Monitor for the Details
THESE ARE THE KEY ELEMENTS IN GETTING OUR MESSAGE ACROSS.

14. Documents to Illustrate Basics
Cleaning Up After the Storm
Reiterate the Biggies
Documents to Illustrate Basics
Clarify Confusion and Misdirection
TO REITERATE THE BIG ISSUES, SITE VISITS WERE MADE BY LDEQ AND EPA TO MAKE SURE THE KEY POINTS IN THE MATRIX AND PROTOCOLS WERE BEING FOLLOWED, AND THAT ANY CONFUSION OR MISDIRECTION COULD BE CLARIFIED.

15. Refreshers on the Basics
Cleaning Up After the Storm
Refreshers on the Basics
Regular Meetings to Update and Communicate New Issues
DEJA MOO – The feeling you’ve heard all this BULL before
MEETINGS WERE HELD WITH LOCAL, STATE, AND FEDERAL AGENCIES, AND CONTRACTOR SUPERVISORS AND UPPER MANAGEMENT TO INFORM AND RE-INFORM ON THE BASIC ISSUES.

16. Monitor for the Details
Cleaning Up After the Storm
Monitor for the Details
Compliance May Seem Complicated
You Are Not Alone
ONGOING SITE VISITS TO KEEP ALL PARTIES INVOLVED AWARE OF THE SPECIFIC ISSUES, LARGE OR SMALL, THAT TENDED TO CROP UP. IT HAS BEEN IMPORTANT FOR EVERYONE INVOLVED TO KNOW THAT THE REGULATORS ARE THERE TO NOT ONLY REGULATE, BUT TO ALSO ASSIST WITH COMPLIANCE AND HELP FIND SOLUTIONS TO PROBLEMS.

17. Is It A Better Mousetrap?
Cleaning Up After the Storm
Is It A Better Mousetrap?
Look Before Leaping
Ask Before Investing
EXAMPLES ABOUND OF INDIVIDUALS AND COMPANIES COMING UP WITH THEIR OWN INTERPRETATION OF A REGULATION THAT DIFFERS FROM THE INTERPRETATION OF THE AGENCY THAT WROTE THE REGULATION.

18. = Repeated Problems Attention Cleaning Up After the Storm
MUCH FRUSTRATION CAN BE AVOIDED BY SIMPLY ASKING FOR AN INTERPRETATION.

19. Cleaning Up After the Storm
Never forget that there are those that are hurting
and need help.