5 Biggest Mistakes in Debris Management

I've worked in debris services for over 16 years as both a debris removal contractor and a debris monitoring consultant. I started after Hurricane Katrina hauling debris to disposal before transitioning to the monitoring side and eventually into consulting. Now, I manage the debris services business unit in one of the country's top emergency management companies. In those 16 years, I've seen several costly mistakes made that can hurt the pockets of state and local governments and effect tax payers. Here, I've compiled a list of the top five biggest mistakes. Some of these are seen more often than others, but all can be detrimental to an applicant’s reimbursement.

1. Truck Certifications

Truck certifications are the first step of a debris removal operation when using contractors to perform these services. If you have a debris monitoring company they need to have knowledgeable and competent staff conducting the vehicle certifications.

In this process, the debris removal contractor’s vehicles' hauling units (truck beds, trailers, etc.) are measured to determine their total hauling capacity. If this is done incorrectly from the start, it can lead to an entire project of improperly quantified loads of debris. Potentially thousands of dollars in de-obligated funding. For example, if a truck is over measured by just 2 cubic yard and that truck removes 100 loads of debris over the course of the project, with an average cost of $8.00 per cubic yard, the hauling contractor would be overpaid by approximately $1,200 for that one truck. With mistakes on more trucks or more cubic yards, this amount will increase exponentially. Most mistakes with vehicle certifications are due to:

• Incorrectly converting inches to decimal inches
• Not deducting reductions such as angles and hoists
• Attempting to measure the hauling unit from the outside
• Certifier inexperience with reading a tape measure.
• Multiplying, Dividing, or Rounding errors

Even for a monitoring firm that relies on technologies such as an Automated Debris Management System (ADMS) to conduct and calculate certified capacities, mistakes can still be made if adequate training isn't provided to ensure the certifier knows how to properly read a tape measure or the certifier fails to include deductions.

To avoid this, managers need to ensure field staff are properly trained, know what deductions are and how to account for them, and a QA/QC process needs to be implemented after the certification to ensure no mistakes were missed.

2. Contract Procurement

Proper contract procurement is the starting place of a FEMA review or Office of Inspector General (OIG) audit. In a memorandum from The Office of Inspector General dated March 4, 2021, the Inspector General finds that contract procurements for debris removal services following Hurricane Irma were possibly not properly followed which may have led to more than $25.6 million in potentially ineligible costs from just one of Florida’s 67 counties.

When procuring a contract that will be paid from federal grant funding, its important that it follows procurement provisions outlined in Title 2 Code of Federal Regulations (CFR) part 200. In addition to being competitively procured and following local contract requirements, this section also requires that you include specific language, federal acts, and/or agreements such as, but not limited to:

·??????Equal Employment Opportunity

·??????Termination for cause or convenience

·??????Davis-Bacon Act

·??????Copeland Anti-kickback act

·??????Clean Air Act

·??????Federal Water Pollution Control Act

·??????Suspension and Debarment

·??????Anti-lobbying clause

In addition to this, its important that your contract contains clear technical requirements for the service, product, or deliverable being procured. Your cost sheet for debris removal should also align with requirements found in FEMA’s Debris Monitoring Guide released March 2001. We’ll discuss one such mistake in item number 4 below.

3. Hazardous Trees and Limbs

Removal of Hazardous Trees and Limbs, often referred to as “leaners” and “hangers” respectively, is the process of removing trees and limbs that meet specific requirements to deem them a hazard to public health and safety. It is also the piece of the removal operation where the most mistakes take place.

According to the Public Assistance Program and Policy Guide (PAPPG) version 4, FEMA defines a tree as being hazardous and eligible if it is incident-damaged and the tree has a diameter of 6 inches or greater measured 4.5 feet above ground level, and the tree:

• Has a split trunk;
• Has a broken canopy;
• or is leaning at an angle greater than 30 degrees.

FEMA defines a hazardous limb as “broken limbs or branches that are 2 inches or larger in diameter (measured at the point of break) that pose an immediate threat”. So, to be eligible limbs must be “hanging over improved property or public-use areas, such as trails, sidewalks, or playgrounds if it could fall and cause injury or damage to improved property.”

FEMA does not fund removal of broken limbs or branches located on private property unless:

·??????The limbs or branches extend over the public ROW;

·??????The limbs or branches pose an immediate threat; and

·??????The Applicant removes the hazard from the public ROW (without entering private property).

Now that we understand what a hazardous tree or limb is, let’s look at a few mistakes found with the removal and documentation of these debris types.

Improperly trained debris monitors will often be persuaded that a broken sapling (young tree, less than 6” at 4.5 feet) is actually a “hanger” (common vernacular for Hazardous Limb) and should be documented as such. This is false. The sapling is a tree but is ineligible for a hazardous tree removal ticket because it does not meet the hazard criteria defined by the PAPPG v4. A hazardous tree can never be a limb and a hazardous limb can never be a tree. This is why I will not use the terms “leaner” and “hanger” and I correct anyone who uses them around me. These terms give “grey area” to new and undertrained monitors.

Another common mistake comes in the form of the chainsaw operators cutting limbs back to the trunk when the break is farther up the limb. This is often done when a branch is less than 2 inches at the break but grows to be more than 2 inches at the trunk. This leads improperly trained monitors to take the measurement at the cut and not the break which is not the operating procedures defined in the PAPPG v4.

The last hazardous limb mistake in this list is made when a chainsaw operator makes a slanted cut on a less than 2 inch limb which extends the surface area of the limb much longer and gives the illusion of the limb being greater than 2 inches. See the image below for a visual aid of a slanted limb cut.

4. Contract Scope of Work and Cost

One of the biggest mistakes made relates to the scope of work and hazardous trees and limbs removal. ?This mistake should be avoided with a proper cost sheet that debris removal contractors bid on. According to PAPPG v4, “For trees that have 50 percent or more of the root-ball exposed, removal of the tree and root-ball and filling the root-ball hole are eligible. For contracted removal of a tree with a root-ball, FEMA will not reimburse two separate unit costs to remove the tree and its root-ball.” This makes it paramount that state, local, tribal, and territorial governments (SLTT) cost sheets include the cost of uprooted tree removal, removal of the stump, and backfilling of the hole as one line item. If the contract does not identify this requirement and allows for multiple costs to be associated to the removal of one item, the contractor may be entitled to additional costs but FEMA may not reimburse for those added costs.

Additionally, the responsibility of properly documenting and overseeing this removal falls on the debris monitor to ensure that the removal contractor adheres to the scope of work defined in the contract. Often times the prime debris removal contractor will subcontract this work out and the subcontractor’s scope of work with the prime will not align with the SLTT contract. Regardless, it is the prime debris removal contractor’s responsibility to ensure the scope of work that they agreed to is carried out in the field and the debris monitoring consultant’s responsibility to differentiate between the two agreements.

5. Documentation and Data QA/QC Protocols

The final common mistake for this list is related to the debris monitoring firm’s quality assurance and quality control protocols. Data collection and management is the primary responsibility of the debris monitoring contractor. They establish eligibility and document the removal. That removal documentation is entered into some form of a database, either via mobile devices with an ADMS or manually entered into a database by data entry clerks from handwritten tickets.

Data is collected and passed through multiple stations along the debris removal process and its important to set up a QA/QC program that takes advantage of those stations. All QA/QC programs should begin with a well-developed and conducted training program. From that point, the debris monitoring firm's standard operating procedure should involve a checkpoint at every station utilizing every position starting with field supervisors reviewing field monitor documentation, DMS monitors reviewing inbound ticket information, data managers or data entry clerks reviewing ticket data in real time as it is made available to them, one more comparison at the end of each day, and a final review during the invoice reconciliation process. A decent ADMS will help establish a QA/QC program and assist the monitoring firm’s management team in identifying mistakes or potentially ineligible tickets.

All in all, every stage of the debris removal process has the potential for mistakes to be made. The most effective way to mitigate these mistakes is with training and education. A capable monitor with proper training can reduce at least 50% of the mistakes on this list. The other 50% can be avoided with proper education of management and SLTT contract procurement.

If you’d like to discuss how my debris monitoring and management team can help you avoid costly mistakes, inbox me here or email me at [email protected]