WEEKLY EDITION OCTOBER 10, 2018
Portable Sanitation and the EPA
Part II cont.
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These rules oftentimes require:
• units be staked down
• plastic liners placed under the toilets
• sandbag berms placed around the plastic under-lined units
• units sit within secondary containment trays to contain wash down water
• industrial absorbent mats be placed under the units
• absorbent berms placed around the units
• on rare occasion, waivers for exemption that are restricted to specific regulated areas such as tribal lands.
Again, these are only some of the requirements PROs face.
While there are often deliberate reasons for these
requirements, as a contractor takes into account the site's
topography, proximity to bodies of water, current degree
of water contamination, population, regional office
requirements, etc., PROs should keep in mind where these
guidelines are coming from.
Because they are probably not coming directly from the
federal EPA guidelines, they may be more flexible than the
customer thinks. It is important to remember that you are
the expert in portable sanitation. While you still need to
meet your customer's needs – both legally and profitably –
there are conversations you can have with your customer
before following a requirement you find unusual.
Combatting misconception and managing your job sites
productively. When bidding a job, it is encouraged that
you ask about the SWPPP and BMP requirements. For
example, if a contractor absolutely requires containment
pans, you will want this on your radar during the bidding
process. Then, try getting to the bottom of the
requirement before making a decision or taking action. Here are some steps you can take:
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