Microplastics: A Persistent Environmental and Human Health Concern

The concern about microplastics is relatively new, probably less that 15 years old. It started with the location of the Pacific Gyre, the large area of floating plastics. The Gyre exists in the Pacific Ocean approximately between the Equator and 50o N Lattitude. Estimates of the size are in excess of 10,000,000 square kilometers. (Wikipedia sourced).

The plastics break down in size, and while some degrade, many do not. The plastics are comprised of a large variety of different substances, mostly made from petroleum compounds. Even at the smaller sizes, the microplastics do not degrade, and they are of a size. The general classification of microplastics is that they are very small, generally less than 5 millimeters (0.197 inches. Many are smaller, in the micron range, (5 microns = 0.000197 inches), which is small enough to penetrate the cellular walls of fish, animals, and humans. Reportedly (unconfirmed), every person in the world has the equivalent weight of a credit card-sized piece of plastic in their bodies. The microplastics can even be found in mother’s milk and in unborn fetuses.

We use lots of plastics. Almost everything we do or eat, plastic packaging, water bottles, milk jugs, etc. contribute some small quantity of microplastics to whatever is contained in them. Microplastics enter the food chain directly because the particles are small enough to penetrate the surface of our food packaging. Once there, they penetrate the lining of our intestines and enter our bloodstream. Of particular concern is what happens as the microplastics enter our brains and reside there. The challenge is that we don’t know what happens yet.

There is, at this time, a lot of research, but very few answers to how to reduce microplastics in the environment. As of 2024, recycling programs are inefficient: less than 17% of recycled plastics are reclaimed and put to other uses, and most are landfilled only to enter our environment through other means.
One only has to research the Internet to find out that many nations have dumped their waste plastics in countries like Ghana, where the Guardian and other major Internet newspapers have horrific photos of the accumulated effect of waste plastics being discarded. I worked in Accra, Ghana many years ago and have memories of walking along pristine beaches now dumping grounds for plastic and other wastes.

Some of the reasons that waste plastics are difficult to reclaim include the variability of the types of plastic materials, differences in melting points, the application of films and coatings to make the plastics resistant to biological attack, and other additives used to change their properties. We use a lot of plastics in everything from water supply piping, to food packaging.

One of the significant challenges is that we are so accustomed to our packaging and the convenience of plastics. We don’t see the plastics shed microparticles, and don’t notice them in our water bottles, our foods and other drinks, but they are there.
This is an area of ongoing research and others and I am looking for economical solutions.

ASTM 1527 and Superfund

What is ASTM 1527? It is the American Society for Testing Materials standard for commercial property real estate transactions. The importance of ASTM 1527 is as follows:

• The first thing to know is that there are laws that regulate liability for disposal of hazardous wastes. The current law which has been in place since December of 1980. CERCLA is an acronym for Comprehensive Environmental Response, Compensation, and Liability Act, and is better known as Superfund. The act was passed largely in response to the community contamination from the Love Canal Waste Disposal Site, located East of Niagara Falls, New York.
• I started working for Hooker Chemicals, the friendly folks who brought you the Love Canal, and I know many of the inside details of its history—a history that the press distorted and improperly covered. However, that’s another story and not relevant to this subject.
• The Superfund Act established 100% liability of chemical and hazardous waste manufacturers for their waste products, “From the Cradle to the Grave!” In short, the manufacturers have absolute liability for properly disposing of waste materials in an “environmentally acceptable manner.” Before the Law was enacted, and for a short while after it was enacted, an environmentally acceptable manner for disposal was thought to be in a specially designed secure landfill that had two layers of chemically resistant liner, and where the wastes were drummed and were surrounded with highly impermeable clay soils. That was the cheapest way to rid ourselves of the unwanted burden of “hazardous wastes.” Kind of an “out of sight, out of mind” mentality.
  If hazardous wastes are found on your site, you will be liable for their excavation and disposal. The cost of that cleanup is measured in thousand of dollars, and can run into millions of dollars depending upon the nature and type of the contamination.

ASTM 1527 comes into play is in establishing an “innocent landowner” defense. Essentially, the provision is that if I purchase a property, I can relieve myself of any Superfund liabilities by performing “due diligence” in looking for evidence of hazardous wastes or disposals on the property I’m purchasing. Due Diligence means having a qualified environmental professional look at the property and researches its history (40+ years or more), examine the surrounding lands, and surrounding industrial facilities, and, if necessary, take soil borings to confirm that the property is free from environmental contamination. The investigation can also consider the possibility of surficial and underground runoff from adjacent sites that have hazardous materials or gasoline-contaminated groundwater from Leaking Underground Storage Tanks.

If I do not have an ASTM 1527 investigation performed, I am absolutely liable for all costs related to the cleanup and disposal of any hazardous wastes that may be discovered after the purchase is completed. Considering that the cleanup and disposal of hazardous wastes can cost hundred to thousands of dollars for each ton of waste encountered. If the groundwater is contaminated, it may require installation of pumping wells and a treatment facility, again a very expensive proposition. The cleanup can also require years of expensive testing. If the site does have hazardous wastes, it could be even more expensive because neighbors and others may have also been exposed to the contamination, and that could generate substantial lawsuits and reimbursement claims for damage to other’s health.

If the contamination has been found to be willful and/or negligent, the State or Federal EPA may impose criminal penalties on the landowner.
The ASTM investigation process has 3 phases, where 1 is the least costly and does not involve drilling nor testing. Phase II and Phase III investigations cost considerably more because they involve subsurface exploration (wells) and expensive chemical testing. Until the ASTM Standard was developed, the business of providing Phase 1 ASTM estimates un-regulated. The bankers underwriting business loans did not understand the need for thorough investigations and were looking only at the cost of the investigation and the investigator’s insurance policy to confirm that it might be sufficient to cover them if anything were found. I have seen bankers ignore the reputation and quality of their investigation contractors and look only at price. In many cases as little as $100 difference between two contractor’s estimates would determine which contractor got the investigation contract.

Some of the contractors, treat ASTM Phase I investigations as a loss leader to get contract. Once on the site, the contractors would seek oil-stained pavement on a commercial site and tell the client that the property needed further extensive investigation, whether it needed it or not. The cost of the additional investigation was always a large multiple of the initial cost estimate.

I have witnessed, and testified against indivduals who took shortcuts and committed fraud. If you don’t know what is going on and have a disreputable contractor, you have given him or her unlimited access to your checkbook. A few examples will help explain:
In suburban Atlanta, a church called me to investigate a contractor’s proposal for site cleanup. The church bought a neighboring property from someone in the construction business. The structure was found to have dynamite improperly stored in the garage attic, and the proposal from the dishonest cleanup contractor contained sampling and analyses of the sand in a children’s playground, and behind home plate on the church-owned ball field. Resampling and proper disposal techniques exposed the first contractor’s proposal as extremely fraudulent.

At one time, Brown Boveri, a large manufacturing conglomerate, had a division that reconditioned large electrical transformers. They had a fraudulent series of Phase I investigations performed on their division locations prior to their sale. The contractor was instructed to conceal the cost of cleanup from PolyChlorinated BiPhenyls (PCB transformer oil compounds no longer in use). The sale was completed before the fraud was uncovered. As it turned out, Brown Boveri was able to complete the sale and then drive the receiving firm into bankruptcy. That action allowed Brown Boveri to escape liability for their contamination.

The Trojan Powder division of IMC had a plant in Springville, Utah. The company was extremely lax about environmental concerns, and that practice led to an acid groundwater contamination problem where the groundwater plume from a leaking acid lagoon stretched for over 3 miles. The lawsuit against the insurance company claimed that the contamination was sudden and unanticipated when it was an ongoing problem the company recognized.
Hooker Chemical Company in Lathrop, California had water evaporation ponds for their process wastes. The ponds were huge, stretching several acres. Hooker thought that chemical precipitates formed from their processes would form an impermeable barrier to prevent wastes from entering the groundwater. The problem was that one could train a fire hose on the precipitate layer, and no runoff would be observed. The ponds contaminated the deep and shallow groundwater in this agricultural area.

Sometimes, even the most innocent practices can lead to potential chemical hazards. Occidental Chemical Company had agricultural feed and supply stores. The stores were located near rail sidings in communities in Texas and Oklahoma. Products were moved by pneumatic transfer—blowing products from the rail car to the storage bins at the supply stores. Because pneumatic transfer caused dust clouds, the plants all injected a light oil into the transfer hoses to keep the dust down. One of the products transferred was ammonium nitrate (NH4NO3) which can be dangerous. When the right amount of oil is added to the compound, it becomes ANFO, or Ammonium Nitrate -Fuel Oil. ANFO was the compound used by Tim McVey to destroy the Murrah building in Oklahoma City. This possibility was dismissed by Occidental Chemical’s Environmental Staff. I raised the issue with the Staff but was overruled. As far as I know, it is still a hazard.

OSHA Compliance Issues

Providing testimony and ensuring that workers are safe on the job is always of high importance. In many instances, selecting the right Personal Protective Equipment (PPE) is paramount in keeping workers safe. It is also important to perform a job hazard assessment to anticipate what the worker may face in a particular situation.

A Confined Space is an area where ingress and egress are difficult and is not designed for continuous habitation. If the confined space has a potentially hazardous atmosphere (high concentration of specific chemicals), contains high levels of CO or CO2, low oxygen concentration, and is a space where the oxygen concentration can change rapidly, the workers should have the air tested and wear proper PPE. In confined spaces, the buddy system is mandatory. The buddy system requires an extra worker to observe and monitor the person inside the confined space, and permits are required to ensure worker safety. Exposure to hazardous chemicals in the workplace should be prevented by monitoring the air and selecting the right type of PPE.

Training workers to be safe on the job is an important part of what I do. I have taught OSHA courses on workplace safety all over the world. I have written several articles on workplace safety and PPE. Many of those articles can be found on this website, and others can be found on Academia.edu.

As with anything, communication is important to protect the general public and gain their cooperation. To that end, there is nothing more frightening than a man or woman in high level protective gear.

Process Safety Management:

Another aspect of the services I offer is teaching industry Process Safety Management or PSM. In the petroleum industry, and in many other industries there is an applicable standard for PSM. It includes job hazard analysis, management of change, provision of safety management plans for a specific facility, and much more. I have taught these course all over the US and world-wide, including Mexico, Qatar, the UAE, Saudi Arabia, Turkmenistan, and in Malaysia.

I have written a book with General Pieter Arlo, SADF, on the subject of safety and security. The book is available from John Wiley Publishers.

I taught courses on job hazard analysis, industrial security, nuclear work and hazards, and a variety of comparisons between the EU and the US requirements for safe chemical facility operations. In one case, I taught security at a Qatar chemical plant. At that time, there was a bit of unrest from the local population and there was concern about attacks on the facility from suicide bombers. The plant Security Office was located by the front gate. I pointed out that having a straight road into the gate would allow persons with mal intent to approach the plant rapidly, and the location of the plant security office above the front gate had a vulnerability if someone wanted to cripple or destroy the plant’s security force. The reaction to my questions was immediate, and within a few days, the plant security force moved their offices to a remote and more secure location. I got a bathrobe from the security force as a way of saying thanks.
In Saudi Arabia, I taught several courses on plant security to ARAMCO’s security force. It was interesting to observe the reactions and questions about how to prepare a security plan for a large oil refinery.

In the process of teaching, I learned several things about some of the Saudi oil refineries. Right before I arrived, the refinery had a 55,000-ton oil spill (1 ton of crude oil= 273 gallons) into a diked area within the refinery. The refinery managed to recover 50,000 tons of crude but allowed 5,000 tons of crude to sink into the ground where it was not to be recovered. The cause of the spill was blamed on the removal of a control valve and the fact that the maintenance crew did not tell the control board operator that the valve was missing. The operator, a cousin to the plant supervisor, proclaimed that the critical valve that caused the spill opened itself. The operator was not disciplined, presumably because of his relationship with the plant supervisor. There was no attempt to recover the oil. Different parts of the world value environmental responsibilities differently.

In the US, I was responsible for developing spill control and emergency response plans for 16 oil terminals throughout the Southeastern US. The area covered included Florida, Louisiana, Tennessee, Georgia, North and South Carolina, Virginia, and Baltimore. In the process, I developed a great guide for spill control planning that is on Academia.edu

PFAS

Per- and polyfluoroalkyl substances – known as PFAS is of current concern. These substances are widely used in industry and in packaging. Fire-fighting foams and chemicals often contain PFAS because the chemicals are heat resistant. Stable thermoplastics used in packaging and in non-stick cookware contain PFAS. PFAS is not one substance but a category of several hundred compounds that have a Fluorine-Carbon Bond which does not break down at high temperatures. There are more than 140 identified PFAS compounds.

The list of regulated compounds includes:

• PFOA (Perfluorooctanoic acid)
• PFOS (Perfluorooctanesulfonic acid)
• PFHxS (Perfluorohexane sulfonic acid)
• PFNA (Perfluorononanoic acid)
• HFPO-DA (GenX)
• PFBS (Perfluorobutane sulfonic acid)

The Maximum Contaminant Levels for these PFAS compounds in drinking water are as follows:

• PFOA: 4 parts per trillion (ppt)
• PFOS: 4 ppt
• PFHxS: 1 ppt
• PFNA: 1 ppt
• HFPO-DA (GenX): 1 ppt
• PFBS: 1 ppt

To give you an idea of how small a part per trillion is, the earth’s circumference is 40,075 KM or 24,901 miles. One part per trillion or 10-12 is equivalent to 0.00157 inches or 0.040 millimeters in measuring that circumference. It’s very small.

The challenge is that the regulatory levels are extremely difficult to measure even with highly sophisticated and expensive instruments. The cost of PFAS Analyses can run to several thousand dollars, and there is currently, no inexpensive nor rapid way to determine concentrations at that level. A typical turnaround time between having a sample submitted to the laboratory and receiving the analytical report on the findings is between 2 and 4 weeks unless you are willing to pay a large premium for rapid analyses.

PFAS can be removed from drinking water by carbon adsorption—running the water through a bed of activated charcoal or biochar. The remaining problem is to regenerate the carbon to destroy the PFAS. Very high temperature roasting of the adsorbent is reliable but expensive. New techniques utilizing wet oxidation under high temperatures and pressures in a caustic medium may hold some promise, but the research is ongoing.

Odor Control and Air Particulates

Odor control and air particulate control are tricky and complex subjects. The atmosphere is a dynamic environment in 4 dimensions, X, Y, Z and Time. Adding to the complexity of the issues, one person’s perfume can be objectionable to someone else. Our noses are sensitive to different things. For example, I can quite often detect chlorinated organic compounds where others cannot.

In controlling odors, one must consider the terrain, the temperature of the emitted gas, the wind speed and direction, and the meteorological conditions. Even with good data, odor control is still a statistical challenge because we don’t do a good job modeling the atmosphere’s dynamics. One of the most reliable measures of odor evaluation is olfactory panels, where subjects are exposed to odors under controlled conditions. The results are subjective because there is no scientific measurement for the odor-causing substance.

In several instances, we have been called upon to evaluate odor complaints from facilities. Sometimes, the simple expedient of tightening up the manufacturing process has been sufficient. In other cases, the facility may have a smoke or vent stack, and the emissions from that stack can create odors at ground level. There are complex regulatory air emission models for the evaluation of the ground-level concentrations of emissions. The evaluation is complex and can be highly subjective.

In two different situations, the clients had to increase the speed of their ventilation fans so that the exhaust air would contain more odor-free air, and the velocity of the air moving up their vent stack would increase the plume buoyancy, allowing for greater dilution of the plume when it finally reached ground level.

In other cases, I have recommended the installation of scrubbers or baghouses for particulate control. As these are individual situations, I will not present details.

Drinking Water

Drinking water should be clean, free from harmful chemicals, and disinfected to ensure its safety. Many parts of the world lack clean water. A successful water supply system has two major components: The treatment plant, and the distribution system.

The treatment plant removes harmful substances and odors from the water, and the distribution system transmits that water to the end user. Treatment plant designs tend to be quite straightforward and are based on the chemical characteristics of the water source. In the US we have some of the best drinking water sources. If the treatment plant is well-maintained and operated, and the water source has reliable quality and quantity, there are few problems. Difficulties can occur when the water source (groundwater or surface water are accidentally or deliberately poisoned with industrial chemicals.

Right after 9/11, I made a presentation to a national water conference that suggested drinking water supplies depended upon the confidence of the user base and suggested ways in which that user base could lose confidence in the water supply system. This was done in a manner to suggest to the utility owners present at the conference that they had much work to do to tighten their systems to prevent terroristic threats. The regional office of the FBI reviewed the technical details in the paper and culled some information from the paper because it could be used to successfully attack water systems.

The distribution system for getting drinking water from the treatment plant into your home is a complex system of loops and connections. As utilities grow, the distribution system becomes more complex and oftentimes overstressed. In the US and in much of the world, the piping is very old, sometimes over 100 years. In rare instances, some municipalities on the East Coast of the US have drinking water mains constructed of wood—something not used for well over 100 years. In each case, balancing the system demands with the supply is challenging. Fortunately, several very good software programs can help analyze a system, telling the design engineers where the inadequate supply pinch points may be, and how to fix them. Some software is free from the USEPA and other sources, and other commercial software programs accomplish the same. I have used both types of software analysis programs and have taught others to use the software to analyze their systems. While the software is predominantly used for large systems, it can also be used for household systems.

Many of the older water systems in the US used lead piping between the household and the water main in the street. The lead was cheap, reasonably inert, and flexible enough to make installation easy. Many years later, the utilities switched to PVC and another type of plastic lines. The lead lines have not been removed in many houses. Lead pipe will leach into the household water system. Lead is a cumulative toxic compound that can damage the liver and kidneys and accumulate in the bones. Lead is a developmental poison for young children and needs to be removed from drinking water. There are EPA standards for lead in drinking water, and removing the service lines is one of the best options.

In AbuDhabi, I was teaching a class on water distribution systems when one of the attendees asked me why their pipe distribution mains were failing at about ½ of the rated pressure. A brief series of questions enabled me to pinpoint the problem. The water was from a thermal distillation system of sea water. The water was exceptionally pure, really too pure to use for drinking. Because the water was too pure, it attacked the asbestos-cement piping, leaching out the calcium from the cement. I was able to show the student a method to prove and highlight the problem for his superiors.

Microplastics are present in almost all drinking water systems. The cause is related to the use of plastic piping in the distribution system and in the household systems. Currently the best solution to remove microplastics from your water is to use a very fine (0.5 micron) water filter system at the point of use. For many, this could require an installation of a faucet filter. If you do not have one and are concerned about the issue, a commercial filter system is available for around $100.00. Be sure to investigate the micron size of the filtration system, even calling the manufacturer if required.

Sustainability

Sustainability is a current buzzword in the environmental industry. In reality, it is the ability of an organism (business or association) to keep thriving and accomplishing its goals even under adverse circumstances. When applied to the environment at large, sustainability can encompass behaviors perceived to be beneficial to the planet and its residents, both plants and animals.

There is one thing about sustainable behavior that is not often mentioned or that, when mentioned, is disparaged as unclean. That behavior is the ability of the organism to make a profit. Profit is necessary for all organisms to get us through the “bad” times when there is no sustenance. Humans often store their profit around their middle as fat. Microscopic organisms store their profit as internal granules for use when there is no food source available.

Even so-called “non-profit” organizations have some reserves to get through the times when their income is delayed or paused. Without that reserve, they would have to fire all employees and go out of business every time the checkbook balance reached zero.

Many organizations receive income in tranches or discrete lumps. Expenses are a continuum and include salaries, communications, printing, etc. One has to balance the income with the expenses and try to anticipate what the next income and expenses will be. If the income is insufficient to meet expenses, the organization has to dip into its reserves.

Non-profit organizations tend to have limits on their reserve funds because they are not allowed to keep those reserves due to the tax rules under which they were formed. Environmental sustainability is the recognition that we all live on “spaceship Earth,” and we have to act responsibly in what we do and how we behave to prevent irreparably damaging the planet.

REMEDIATION and Ground/ Groundwater cleanup:

I have written 3 books on remediation. The first one dealt with petroleum contaminated sites. The last two were more general and addressed topics like cleanup of contaminated soils and groundwater. The books have been well-received. I get occasional mentions as references. I even assist a professor friend in Italy with her class, teaching a few lectures on remediation.

The latest book, Remediation Manual for Contaminated Sites has a few different features that will be of use to the practitioner. I’m a strong believer in aggressive management of a site where it is economically feasible. I balance that against a desire to see phytoremediation systems work when and where feasible. My book has a chapter on selection of the best type of plants for extracting contaminants from the ground. Phytoremediation is a very slow process, but it has the advantage that it is less disruptive to the soil environment.

Another chapter in the book deals with Ecosystem remediation and rebuilding. While working on a project for Nigeria, I took the United Nations Ecosystem Restoration course. It has many helpful suggestions about how to manage and restore an ecosystem, and consulting with the indigenous populations to address their cultural and other needs as they pertain to the ecosystem.

In performing any type of remediation activity, one must have a good, short turnaround laboratory to be able to tell the workers and supervisors when the extent of the remediation has been completed. Access to a short turnaround laboratory is critical. In the United Nations Environmental Program investigation of the massive petroleum contamination of Nigeria, the UNEP crew was severely hampered by the lack of analytical equipment within the country. As a result, they had to send samples up to Europe for analyses, and the results might not be returned for a month. It is like trying to drive your car by looking only in the rearview mirror.

The book also addresses the subject of public and community relations in two areas: the initial investigation and in cleanup. Because I feel strongly about these issues, I’m reproducing the material here:

• Public Relations

  • Two quick points from the investigation chapter of book are: 1) during every phase of the investigation, be sure to provide potentially affected persons with information about your activities and purpose; and 2) be sensitive to community comments and complaints, and respond to them quickly and accurately, even inviting others to observe your activities.
  • I believe that I have written that there is nothing quite as terrifying to a community than to have technicians dressed in fully or partially encapsulating clothing with self-contained breathing apparatus walking around on one’s property when you don’t know what they are there for or what their instruments are measuring. How much of a hazard are you in by living where others are fearful of walking and breathing your air?
• Later on, when discussing cleanup, I offer this advice:
  • The public is often interested and concerned when they find out that a remedial activity is planned for their neighborhood. Understandably, there is fear and uncertainty about what will be done and whether or not the contamination will be airborne, waterborne, or something else which could degrade their way of life. It is something that has to be handled in as gentle and understanding way as possible to avoid unnecessary intervention and opposition.
  • There will always be at least one voice or group that opposes the activity, without regard to the benefits of what the remedial activity will accomplish. If not handled properly, the opposition can result in nuisance tactics, public opposition, political activity, continuous regulatory scrutiny, and even sabotage and violence. The degree to which hostilities escalate is up to the management of the remedial project.
  • Look at the history of the site and attempt to determine how the contamination got there. Sometimes, explaining the site’s history will help placate the community. In other cases, the site’s history is often ignored.
  • With old industrial sites, the industry that generated the contamination will have allowed “fence-line communities” to develop. These communities may have been company built for the plant’s employees or may have sprung up on their own. Either way, the issue will be contamination and noise to the residents because the original company did not purchase enough ground to allow for potential contamination of residences from the company activity[1]. With older neighborhoods, this housing has changed hands a number of times, may be in need of repair, and the social class and ethnicity of the occupying community may have changed.

• • Sometimes the residual population is less fortunate or poor, and angry about their lifestyle. They will oppose anything that they perceive may adversely affect them, with or without any information about the activity or its consequences or improvements for them.
  • Plan on developing a community outreach program. Attend public meetings, conduct worksite tours if possible, and identify and talk to the community leaders before the project is initiated. Seek to employ some local personnel where possible. Provide community briefings on a periodic basis. And the site managers must put themselves in the “shoes” of the residents to understand their daily lives and how they perceive the activity.
  • Site management must consider noise and dust and vapor effects on the community as well as the visual impact of the remediation project. On a contaminated site, the workers are often dressed in Tyvek® coveralls for protection against dusts and accidental splashes. There is nothing more terrifying than a white-suited worker making measurements in or adjacent to a residential community without prior explanation![2]

• • Public relations firms can provide good community contact, and so can local residents. In a South American Country, in an area where the indigenous population was native, tribal, and ethnically different from the government of the country, several local native representatives were hired to perform pre-contacts to gain permission for the survey team to come on private land and conduct contamination surveys. In addition, members of the survey party included at least one local representative from the community. The local representatives were young highly-educated women who not only spoke several languages and dialects but who could provide assistance with the technical work. The investigations were conducted without incident.
  • Keep lawyers away from remediation projects. Lawyers do not think technically nor understand the nuisances of technical work. (Occasionally they do not know or understand the regulations either!) The lawyers should be consulted if there are lawsuits or contract disputes. Lawyers think legally and often act confrontationally. Confrontation is unnecessary when community relations need to be improved. Lawyers do not work to your time schedule and are often constrained by the schedules of judges and opposing counsels. Legal proceedings slow the pace of the work and can add significant additional expense to the project.