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The Industrial Site Recovery Act (ISRA) is in place to ensure that industrial sites of certain NAICS codes that undergo transfer of ownership or cease business operations investigate whether or not the facility needs remedial action. The purpose of this act is to protect new owners from inheriting environmental issues such as spills or contaminated soils. These types of issues can cost new owners millions of dollars in remediation.

Once a site has declared its intent to cease business operations or a sale of the property is concluded, the ISRA clock starts immediately. The first item to be completed is the General Information Notice, commonly referred to as the GIN. This form must be completed and submitted within five (5) days of the various triggers (listed in subchapter 3 of the ISRA regulations).

Following submission of the GIN, a Preliminary Assessment (PA) must be performed. This report is prepared by a Licensed Site Remediation Professional (LSRP). The purpose of the PA is to identify and assess all areas of concern. The PA is a limited investigation that identifies whether or not the site poses any threat to the environment or human health or if it is a site that requires further investigation.

Following the PA, a determination is made on whether or not a formal Site Investigation (SI) is required for any of the identified areas of concern. The SI typically includes soil and/or groundwater sampling of any areas of concern that were determined to require further testing. For facilities requiring Site Investigations, remediation may be required if soil and/or groundwater testing show levels of contamination above allowed background levels.

If you think your company is preparing to undergo one of the triggers for ISRA, it is important that you ensure you are prepared to meet the short reporting deadlines. If your company is getting set to undergo one of the triggers for ISRA, give Baron a call.

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