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Re: GP sampling
> From: Delores Broten <dbroten@rfu.org>
> To compare GP "stealing" samples of streams of waste which are going
> into the public water and air, with industrial espionage for private
> profit, is pure sophistry.
The problem with "stealing" samples at the source is that a certain
amount of legitimacy is lost whether we are willing to recognize it or
not. Just as the industry can falsify data, so can the activist. The
activist's data may be absolutely correct, but without the same level
of standards with chain-of-custody, field notes, and documentation, the
court or regulatory office has the same obligation as if that
information came from industry - the data would be void. Most
industries do not faslify data, but enough do (whether on purpose or by
incompetence) that the average citizen has ample cause to be worried
about the data. The laws are written to catch and punish this type of
falsification, but the enforcement officers a) are overworked b) have
to know where to look. Sometimes industries are caught, many times
they are not.
ONE Solution: Whether many of you realize it or not, technology has
quickly ramped up to a stage of answering these questions without
touching foot on the facility. Whether we are talking about fenceline
monitoring for air emissions, open path FTIR, or taking waste stream
samples, there are ways to do this legally and still prove that a
company is in violation of its air/water/waste permits. So instead of
relying on enforcement personnel, which are overworked (and some of you
could care less for), you could become more active in the enforcement
role (instead of reviewing paperwork supplied by the industry itself)?
Maybe we/you should be thinking about coordinated efforts to bring
together a testing group that can approach this problem actively,
accurately, and honestly, with the full weight of the law AND science
behind them? Very few organizations can fund even limited sampling
efforts. But a coordinated effort by all could field a small team and
keep them busy year round to the benefit of all concerned.
Food for thought.
Sam McClintock
scmcclintock@ipass.net