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Crosswalk Between 40 CFR 312.10 Definitions of “Environmental Professional” and the IHMM CHMM Requirements and Specification Blueprint

Questions often arise as to which governmental agencies recognize the Certified Hazard Material Manager or “CHMM” to perform various work functions under their statues. The IHMM Board continues to champion such recognition and recognition of our other certifications, but seeking this type of recognition is often time consuming and costly. Some governmental bodies will produce their own certifications, such as a Certified Professional (“CP”) in Ohio, to take advantage of voluntary clean-up of regulated sites. Still other agencies don’t recognize any professional per se or are content to use the certifications that were fortunate enough to be included in the earliest versions of the regulations. Others may recognize certified persons after work by the IHMM, but then the whole universe of certified professionals want to “piggyback” on our work, with the claim that their certification should be included in the regulations. Worse yet, some licensing or certification bodies will actively work to have only their licenses or certifications included or protected, even to the extent of excluding others, such as CHMM’s, even when CHMM’s are capable of doing the work..

The IHMM Board often finds itself in the position to work or “partner” with related certification associations to advance certification or even protect against the unauthorized use of a professional certification, on the federal and state level. This sometimes extends to regional or even local agencies tasked with protection of the health of the public. Indeed, advocating the benefits of certification can involve finding a sponsor for such legislation, getting the governmental body to make this a priority activity and then completing such work inside of one administration’s term or biennial session of the legislature.

Fortunately, Eugene A. Guilford, Jr, Executive Director of the Institute has pointed out that CHMM’s are “Environmental Professionals,” under the analysis of US EPA regulation 40 CFR 312.10. This analysis has been posted on the IHMM website, but merits reposting here. Please take a few minutes to read through this analysis. You can then use it to procure services or inform your client that they should adopt 40 CFR 312.10 when procuring services, in general, if they cannot require the use of a CHMM in particular.

You may read the IHMM – CHMM crosswalk here.

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Written by Mark Baumgardner, CHMM

Created: 03 May 2022

Last Updated: 03 May 2022