Interim Guidance for Public Meetings During COVID-19 Public Health

Emergency

PCB Cleanup, Storage, and Disposal Program1

As of April 9, 2020

In keeping with EPA's commitment to provide meaningful public engagement in the environmental
decision-making process, while also ensuring the health and safety of our staff and the communities we
serve, the Office of Resource Conservation and Recovery (ORCR) is providing interim guidance for
conducting public engagement in the polychlorinated biphenyls (PCB) cleanup, storage (prior to disposal),
and disposal approval process during the Coronavirus Disease 2019 (COVID-19) public health emergency.

EPA, as a practice, conducts community engagement, including public meetings, for certain PCB cleanup,
storage, and disposal approvals that could affect the community. EPA uses national and regional policies, as
well as site-specific considerations like community interest, to guide when and to what extent community
engagement may be appropriate for each relevant PCB cleanup, storage, and disposal approval that the
Agency issues.

This interim guidance provides alternative approaches, recommendations and resources to help ensure
public participation when in-person meetings are not an option. It is developed in consideration of current
guidance from the Centers for Disease Control (CDC)2 and may be updated based on new information.

Interim Guidance

•	EPA recommends that Regions use virtual alternatives, where feasible, in lieu of in-person public
meetings, site visits, and other facility-related face-to-face public interactions. Regions should not
hold in-person public interactions, consistent with current Federal, State, tribal, and local COVID-19
guidance on events, mass gatherings, and social distancing. Regulators should check the CDC
Website3 for the latest federal guidance and maintain awareness of the most current guidance from
state, local, and tribal public health and governmental officials. Since many of these guidelines are
being updated frequently to respond to changing conditions, EPA advises regulators to avoid in-
person events during this period of significant uncertainty to avoid any last-minute changes to
meeting plans. The Agency will assess the continued need for and scope of this policy on a regular
basis and will update it if the EPA determines modifications are necessary.

•	ORCR fully encourages EPA staff to keep in contact with affected communities using other
communication channels such as fact sheets, phone, social media, etc., as well as using virtual tools
such as on-line meetings, webinars, conference calls, and call-in numbers.

•	In circumstances when public meetings have typically been held in-person, following EPA policy,
Regions should use, where possible, virtual public meeting tools.

•	Before considering using a virtual meeting tool, please ensure meetings are properly planned to
promote access and effective communication, to the extent practicable (see tools referenced below).

1 https://www.epa.gov/pcbs

23 https://www.cdc.gov/coronavirus/2019-ncov/communitv/large-events/index.html

1

United States
Environmental Protection
Agency


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•	Even while EPA is encouraging the use of technology for virtual meetings and communications, staff
should keep in mind that some individuals may have only limited or no access to internet or other
technologies, or to necessary Agency documents (e.g., Administrative Record File), especially during a
time of social distancing. For example, libraries that serve as information repositories or that provide
a method of internet access may be closed. Therefore, Regions should take steps to ensure, as
practicable, that participants can follow the substance of discussions even if they lack full access to
the technology and/or Agency documents (e.g., by also providing access via telephone and/or mailing
necessary documents).

•	PCB Regional Coordinators should also consider postponing public meetings and other site-related
public interactions when there is no viable alternative for a meaningful public discussion due to lack
of internet or other technology.

Public Meetings

Virtual public meetings should be held, when possible, as a substitute for in-person public meetings during
the COVID-19 public health emergency. Information on tools to enable virtual meetings is contained in the
attachment "Hosting Virtual Events."

•	Prior to issuing a final approval for a PCB commercial storage or fixed-site disposal facility, EPA
publishes the draft approval and conducts public engagement. This engagement often includes a
presentation by the facility and an open Q&A session in a public meeting, and the opportunity to
submit comments on the draft approvals.

•	Public meetings are also provided by the Agency when there is a high level of public interest (based
on requests) during the draft approval stage, a major approval modification, or renewal involving a
major modification. They may also be held on a voluntary basis and strategically planned to promote
community engagement.

•	Public meetings should be announced at least 30 days prior to the event. The public meeting notice
may be combined with the draft approval notice.

Tools and Resources

For more information that may be relevant to the PCB cleanup, storage, and disposal program, please
consider the following resources.

•	The EPA's public participation guidelines for RCRA Public Meetings are detailed on Chapters 2, 3 and
4 of the 2016 Edition of the RCRA Public Participation Manual, which is available at:
https://www.epa.gov/sites/production/files/2019-09/documents/final rcra ppm updated.pdf.

•	For further information or assistance, please contact Karen Swetland-Johnson at swetland-
iohnson.karen(a)epa.gov or Lilybeth Colon at colon.lilvbethffiepa.gov.

2

United States
Environmental Protection
Agency


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