What is the ITRC state concurrence process?
State
concurrence is the formal review and documented acceptance of the willingness
to use/test ITRC Technical and Regulatory Guidance Documents. The Point of
Contact (POC) in each ITRC state is responsible for having the appropriate
personnel in their state agency review the ITRC Technical and Regulatory
Guidance Documents and to provide their state's level of concurrence on each
document. The POC will then send a letter to the ITRC State Engagement
Coordinator indicating their state's level of concurrence on the specific
document. This information is maintained and updated in a concurrence matrix.
The intent is to provide concurrence information to document users via the
website.
Why is the concurrence process important?
The
concurrence process serves as a formal mechanism to gain state commitment to
use the ITRC products and services. In addition, concurrence on ITRC Technical
and Regulatory Guidance Documents provides predictability for parties wanting
to use an innovative technology in an ITRC state.
Who should sign a concurrence letter?
This is up to each
state on an individual basis depending who has been designated in their state
to serve in that role. The preference is to have the highest-level management
personnel in the state's environmental agency sign off on a letter of
concurrence. We have received concurrence letter from a variety of management
levels (e.g., agency directors, program managers).
Where should state concurrence letters be sent?
Please
send state concurrence letters on ITRC technical and regulatory guidance to the
ITRC State Engagement Coordinator:
Mr. Paul Hadley
California Dept. of
Toxic Substances Control
P.O. Box 806
Sacramento, CA 95812-0806
P
916-324-3823 / F 916-327-4494
phadley@dtsc.ca.gov
Which documents is the ITRC requesting formal concurrence on
and what is the current status on the document concurrence?
The ITRC is
requesting formal concurrence on all ITRC Technical and Regulatory Guidance
Documents produced by ITRC technical teams. A list of these documents is
attached and includes the current status by state and the level of state
concurrence submitted.
What are the levels of concurrence?
| A = | We concur. We agree that the requirements/guidelines are appropriate and commit to using them to the maximum extent feasible. |
| B = | We agree that the requirements/guidelines are appropriate; however, we cannot commit to level A concurrence for this reason: (state response) |
| C = | We do not concur with the requirements/guidelines for this reason: (state response) |
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