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 5 1 Ask, "Whose requirement is this?" The common answer will be "the EPA," but you've now learned that this is unlikely. Ask for a citation if they feel that a requirement directly stems from the agency. For example, the EPA does not specifically require staking – even with most state EPA rules, the written recommendations are not that specific. If the regulation states that a unit must be "secure" to ensure it will not be tipped or knocked over, recognize that this is not the same as requiring a unit be staked. Dig deeper about the reasons behind the requirements. 2 Ask them if what they are requesting is stated in the SWPPP or BMP. These are more easily adjusted than laws. If your customer understands the difference between what is and is not legally required, they are often much more willing to talk about options and listen to potential recommendations. Discuss with them what is actually relevant at their particular job site due to the topography, proximity to water, etc., and propose suggestions based on these factors. This may present some valuable contrast between the SWPPP/BMP author's take on the EPA guidelines and your professional opinion as an industry operator. 3 Educate your customer when you see a misperception. Contractors may have jumped to conclusions on how to best follow EPA guidelines. For instance, the SWPPP and BMP requirements may be skewed under the mistaken idea that portable restroom waste is "hazardous." The EPA categorizes portable restroom waste as "domestic septage," not as "hazardous waste." Unless you are charging or cleaning your toilets with something categorized as hazardous, the rules pertaining to hazardous waste do not apply to your units. It is easy for those outside of our industry to misunderstand what things like stakes, containment pans, and mats actually accomplish. Take the time to explain these things to them so that you can come to a common agreement on what is actually needed or what would work best. CONTINUED ON PAGE 9 PAGE 7