Portable Sanitation Association International

94 2019 INDUSTRY RESOURCE DIRECTORY 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. Get your facts in order ahead of time—both generally about what laws and requirements actually apply in your area, and specifically regarding the most common requests listed above—and you'll be more likely to succeed with the customer. Combatting misconception and managing your job sites productively. When bidding a job, it is a good idea to 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. • Ask, "Whose requirement is this?" The common answer will be "EPA," but you know this is unlikely. Ask for a citation if they feel that a requirement directly stems from the agency. For example, 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. 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 EPA guidelines and your professional opinion as an industry operator. • Educate your customer on where 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." Portable restroom waste is categorized by EPA as "domestic septage," not as "hazardous." 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 an agreement on what is actually needed or what would work best. • Assist them in following the rules while saving money where possible. If your customer still feels that some "extras" are necessary after you've taken the time to discuss their proposed requirements, take them through the options. As stated, help them to understand what certain extras will or won't accomplish. For example, make sure they are aware of the pros and cons of staking versus tying down or binding units in groups. Explain deodorizer options and their chemical composition. Give them your recommendations and the costs associated with each. It is inevitable that there will be discrepancies between what is required and what is not, considering EPA's intent to allow for interpretation. The most effective way to combat misperception is proper education. If you take the time to have a discussion with your customer about what is required for your units, you both will feel confident doing business together and you won't lose control of your job sites due to unnecessary "requirements." EPA and Portable Sanitation Better worksites. Better weekends. Better world. EXCLUSIVE MEMBERS-ONLY CONTENT REDACTED Join us now at www.psai.org for access to this valuable information.

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