To the guidance documents

What is required for a CSM?
A CSM describing potential exposure pathways is an important tool for evaluating the risks that may be present at a contaminated site. Because many consultants do not routinely submit CSMs, the DEC recently issued a directive requiring that a CSM be documented for every site.

The DRAFT CSM Guidance states that a human health CSM should include:

1. a graphic of the exposure pathways at a site, and
2. text describing each element of the CSM.

A preliminary CSM should be included with the site characterization work plan and revised as needed in each site characterization report.

Why was a CSM Guidance developed?
CSMs are based on many different assumptions. The CSM Guidance was developed to standardize some of the assumptions that are made in the early stages of site work.

When should the Human Health Scoping and Graphic Forms be used?
The forms are not required. They are intended to help consultants complete the requirement for a CSM on all sites. The Human Health Scoping Form ensures that consultants are evaluating whether pathways are complete or incomplete in accordance with the DRAFT CSM Guidance. Once the DEC project manager approves the Human Health Scoping Form, the Human Health Graphic Form can be used to meet the requirement for a graphic of the exposure pathways at the site. These forms will probably be more useful on simple sites or on sites in the early stages of investigation.

Do the forms include ecological pathways?
The forms do not address any pathways that are typically covered in an ecological risk assessment. The DEC has developed a screening approach for ecological risk -- this approach is explained in the Ecoscoping Guidance. An ecological CSM is not required until after ecoscoping has been completed. In some cases, ecoscoping will indicate that no further ecological evaluation is necessary and an ecological CSM will not be required.

Can a completed form be included in a report electronically?
If you wish to add the form to a report, take the following steps:

1. Fill out the form using Adobe Acrobat.
2. Save the form as a .jpg file (choose .jpg as the extension during the save as command).
3. Insert the form into the report as a picture.

Note: Completed forms can only be saved using Adobe Acrobat. Acrobat Reader will not allow you to save completed forms. If you only have Acrobat Reader, you will have to print the completed form and scan it to create an electronic copy.