Issue link: http://psai.uberflip.com/i/1084319
92 2019 INDUSTRY RESOURCE DIRECTORY EPA and Portable Sanitation • Know your local limits. EPA and local rules generally concern themselves with three aspects of the biosolids in your load: metal concentrations (pollutant limits, ceiling limits), pathogen control, and vector attraction reduction. Most of the calls to the PSAI from operators are about metal concentrations, because treatment facilities are warning that load levels are "too high." In reality, the amount of metal concentrations in your load will vary depending on a number of factors—most outside your control. Heavy metals are natural components of Earth's crust. They cannot be degraded or destroyed. To a small extent they enter humans via food, drinking water, and air. Heavy metals can enter a water supply by industrial and consumer waste, or even from acidic rain breaking down soils and releasing heavy metals into streams, lakes, rivers, and groundwater. Human waste plus the concentrations in your prefill plus any extraneous sources of metal combine to give you the levels in your load. The main thing you, as an operator, can do is understand the local metal limits and what, if anything, you can do to reduce the concentrations in your loads. Sometimes dilution is the solution. Sometimes finding another legal disposal option is the answer. PSAI round table discussions are great ways to find out how others have addressed similar issues. • Know what's on your truck. Generally speaking, portable sanitation waste is considered domestic septage, not hazardous waste. However, depending on a variety of rules, some deodorizers and cleaners can impact how your load is classified. This can make a big difference at the treatment plant, and it can also greatly affect the situation on the ground if you have a rollover or sizable spill. Read the Safety Data Sheets (SDSs) and compare the ingredients of products you are using with local limits. Then talk to your suppliers of deodorizers and cleaners. Time spent understanding how their products affect the classification and numbers associated with your load can save you time and money. Quite often you will find your supplier can help you navigate difficulties with your disposal site, as well. Most are very experienced in doing just that and would be glad to help you. When customers cite "EPA Guidelines." When interacting with contractors and inspectors, it is common for a PRO to feel caught off guard when suddenly told of a requirement that they haven't previously encountered. Whether this is a customer's adamant requests that the PRO provide containment pans or that they stake all units down, if the operator has not been instructed to do so "by requirement" in the past, red flags will rise and they'll often turn to the PSAI with concern. The insistance tends to come from a customer's knowledge of EPA requirements—or lack thereof. EPA requirements are commonly misconstrued for a few reasons, which can result in misled customers and confused PROs. • Discern EPA requirements versus local recommendations. First, it's important to remember what we stated earlier: EPA, at the federal level, does not actually make requirements for the portable sanitation industry. Instead, EPA mandates that every state have a plan for avoiding pollution that exceeds federal limits on the construction job site. What matters here is actually how your state or local law upholds EPA guidelines. In fact, most of the time, portable toilet guidelines as they apply to construction sites are few and simple. As EPA allows their guiding principles to be interpreted Better worksites. Better weekends. Better world. EXCLUSIVE MEMBERS-ONLY CONTENT REDACTED Join us now at www.psai.org for access to this valuable information.