Portable Sanitation and the EPA
Part II cont.
KOS CONTINUED FROM PAGE 2
And considering that OSHA requires portable restrooms on construction sites, your portable units will factor into a
contractor's SWPPP and BMP.
When a contractor is creating these documents they must follow their state and local laws when dictating the
specific guidelines for their site's portable toilets. Yet when you factor in different contractors in different states
and regions, with differentiating job site topography, no SWPPP or BMP will be exactly the same when it comes to
the section on sanitary or septic waste management.
These situational differences are precisely why PROs suddenly face new "requirements" from customers that seem
to come from the EPA. The truth is that EPA mandates pollution limits and provides guidance on how to create
BMPs that fulfill the intent of the Clean Water Act – but the content of the BMPs is driven by state and local
pollution limits. These local limits may be more stringent than federal EPA limits. So might the practices and risk
management strategies of
the general contractor
who is negotiating a
contract with your
company.
What you will likely
encounter. Considering
that there is no
"cookbook" for creating a
BMP – only an approval
process when applying for
a Construction General
Permit – there are going
to be plenty of variations
on the plan. However, the
PSAI has found that the
following "unusual"
criteria for portable
restrooms are fairly
common when the local
environmental limits or
tolerance for risk are low.
WEEKLY EDITION OCTOBER 10, 2018
PAGE 3
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