Issue link: http://psai.uberflip.com/i/1037945
WEEKLY EDITION OCTOBER 10, 2018 Portable Sanitation and the EPA Part II cont. KOS CONTINUED FROM PAGE 1 confused PROs. In this article, we will highlight how and why the rules in place are misinterpreted, how this can affect your job sites, and what you can do to appease your customer while saving you both money. EPA requirements versus local recommendations. First, it's important to understand that EPA, at the federal level, does not actually make requirements for the portable sanitation industry. Instead, the EPA mandates that every state have a plan on the construction job site for avoiding pollution that exceeds federal limits. What matters here is actually how your state or local law upholds EPA guidelines. Most of the time, portable toilet guidelines as they apply to construction sites are few and simple. As the EPA allows their guiding principles to be interpreted by states, each state tends to also create rules for implementation that are left intentionally vague to allow for inventiveness. How rules are mandated locally will greatly depend on what suits local job sites, companies, weather conditions, and regions of interest – both the EPA officials and writers of state legislation understand this. How this freedom leads to confusion. Because of the intentional room for interpretation, much of the responsibility for an up-to-code job site falls on the contractor. Under EPA's Clean Water Act, contractors are required to create and submit a Storm Water Pollution Prevention Plan (SWPPP) to their state-level agency when they apply for a Construction General Permit. In this document, the contractor must identify the sources of pollutants that will create contaminated storm water run-off at the construction site. Along with the SWPPP, they must also develop a plan or handbook entitled "Best Management Practices (BMPs)" which highlights a schedule of activities, prohibition of practices, maintenance procedures, and other management processes that are intended to prevent or reduce the possibility of water pollution at the job site. CONTINUED ON PAGE 3 PAGE 2