Ohio EPA has recently announced a new policy of rotating personnel within its districts and divisions. The new policy will apply to inspectors and staff, but will not apply to management.
The policy is intended to provide Ohio EPA staff with a wider range of experience and technical skill.
"As many of you know, creating professional development opportunities in any area of business is essential to maintaining a well-rounded organization. Many of you in the private sector offer your employees these opportunities and we are implementing a similar strategy in an effort to streamline our operations and improve the depth and breadth our employee’s knowledge."
A second letter was sent by the Division of Surface Water announcing how the new policy will impact staff charged with reviewing Permits-to-Install and NPDES permits:
"The Division of Surface Water (DSW) staff assignments will change in the National Pollutant Discharge Elimination System (NPDES) and permit-to-install programs approximately every five years. For NPDES permittees, this means the same staff person will likely complete one permit renewal since renewals are required every five years."
Having worked with many Ohio EPA inspectors both while at the Agency and since working in the private sector, it will be interesting to see how the new policy is received. As expected with every large organization, there is array of expertise, temperament and communication styles among inspectors and staff.
For facilities and business that like the inspector assigned to them, the new policy will likely not be seen as good news, especially if the newly assigned inspector isn’t viewed in a positive light. For those that have been frustrated by their current inspector or permitting staff, they may welcome the change.
While rotating personnel will certainly provide a wider range of experience to staff. It will also have the effect of shifting institutional knowledge. Some sites and facilities are very complicated. It may take a few years for staff to fully understand all the operations or issues.
Rotating staff could mean that businesses experience some level of frustration when trying to "get the new person up to speed." Perhaps, Ohio EPA will try and accommodate these situations by maintaining continuity at these more complex sites.
If I had to predict, the Agency will likely get more calls complaining about the policy then praising it. Most people only call when they are frustrated or don’t like a change.