You can’t manage what you can’t see. Poorly Managed Environmental Inspections, Action Items, Documents and Maps = HEAVY FINES & PENALTIES
Where are your Stormwater or SPCC Plan inspections? Do you have instant access to them so that you can see if they are even being done? Do reports contain open and closed action items by dates? Are these plans accessible to anyone that needs to view them? Do they contain current regulations, permits, proper certifications or other necessary items? Are specific components like maps and specifications being properly updated?
These are questions that industry professionals are presently considering as a growing emphasis is placed on environmental compliance and enforcement in our communities nationwide. Ready mix batch plants and other related concrete production facilities take no exception to this. For example, most plants and production facilities have to manage a Spill Prevention Control and Countermeasure (SPCC) plan due to the qualifying amount of fuel, oils, and other petroleum related products used on site. As well, a Stormwater Pollution Prevention Plan is required by the Federal Clean Water Act on most concrete production facilities that have exposures to rain or snow melt. Federal, state, and or local regulations are very specific when it comes to how these plans are managed. After all, these plans become the “court documents” in the case of a regulatory review, derived of self-monitoring documentation that is required by their complicated regulations. As inspection and documentation demands within these regulations grow more complex, coupled with both ever increasing regulatory oversight and a social consciousness of environmental concerns that has everyone under the microscope, companies are desperately trying to solve how to best meet them to stay compliant and avoid the negative publicity, costly fines and penalties that are on the rise. All of this, while trying to build profits. Does this current state of affairs not beg the simple questions of how and what to do?
So, what is the best way to efficiently manage these plans legally with their ongoing inspections, documentation and reporting?
While many environmental regulations can seem burdensome, the regulations also allow some
common-sense methods for achieving compliance. One such method allows technology to be implemented to perform inspections with electronic signatures, creating and communicating action items, electronically updating maps and the overall electronic management of all environmental documentation, management, and communication. Company management personnel have been trying to figure out the best way to perform and manage components within these regulations on site for quite some time. Mailboxes, lockboxes, spreadsheets, handwritten checklists/notes, and other methods have been painstakingly used to try and meet these regulations. However, as you can imagine, inspections are often missed, action items are not noted or communicated, and maps/plans commonly go unkept. In some instances, these federal documents are even lost, vandalized, stolen, mismanaged, weathered, and ultimately not compliant. Company management personnel often struggle when emphasizing the need for continual upkeep and management of the SWPPP and SPCC, especially if the only way to see if plans are being managed and inspections are being performed is to actually drive to the site to view what is going on! When this is the case, compliance accountability, due to the lack of accessibility and verification, takes a dive while liability risk skyrockets; thus becoming a major problem for any company, let alone companies with multiple regulated facilities and operations. And, it appears that the federal government is ready to require states and local municipalities to manage programs like the NPDES (National Pollutant Discharge Elimination System – Federal Clean Water act) electronically. This would certainly encourage anyone wanting to comply to utilize technology to save everyone money and time in the process.
Online software that will enable companies to perform inspections, document action items, update maps and other documents while managing it all electronically is more sustainable and provides a much better way to manage an environmental program more efficiently and make it compliant. This concept is the very beneficial essence of implementing technology. As long as the way to electronically access updated plans, completed inspections, action items, and documents are posted with the permit, your site is complying with the law. The benefits of utilizing technology for electronic management are obvious. Never has there been more incentive for the implementation of technology to enhance operational processes than this day and age where everyone has a smartphone, tablet, or access to a laptop or computer. Three ring binders and hard copies of the plans, inspections, and all that other stuff are a thing of the past. Electronic performance and management of all things environmental is the process of the future, no different than our online banking accounts or filing our taxes electronically. This increases profitability, provides more flexibility, and drives improved compliance.
Consider these advantages when utilizing technology to manage your Environmental Program
Correct Inspection Form for Each Permit to be Utilized, Managed, and
Inspections and Management on Any Device - A Paperless Process – Saves Time and Cost
Correct Inspection Frequency for Each Permit
Adaptable Inspection Forms in Real-Time When Changes Need to Occur
Directives on Inspection Forms and Action prompts can help ground operations comply
Drive Action Items Electronically for Communication and Completion
Create, Amend, Update Key Maps/Drawings, Etc.
Platform for All Compliance Documents-Readable, Accessible, Retainable
Training Modules Available 24-7 - Operators Access When Convenient for Them
Run Reports for Quality Control and Employee Evaluations
Quantify Action Items by Open and Closed Dates - Run Key Reports to Properly Manage this Cycle
Closes communication Gaps of non-compliance from ground operations to management
“The Eye in the Sky” - You Can’t Properly Manage What You Can’t See
Protect Company and Personal Risk Management - Closes Compliance Gaps in Any Program
Online SWPPP Management Where is your SWPPP? Is it accessible to anyone that wants to view it? Does it contain the current permit or proper certifications? Is your SWPPP being properly amended/updated when you perform required ongoing inspections?
These are questions that construction professionals and MS4s are presently considering as a growing emphasis is placed upon water quality and enforcement in our communities nationwide. A SWPPP is a Stormwater Pollution Prevention Plan and required by the Federal Clean Water Act on most construction sites including industrial facilities that have exposures to rain or snow melt. Federal, state, and local regulations are very specific when it comes to how these plans must be properly managed. After all, the SWPPP document itself is the “court document”, derived of self-monitoring documentation that is required by their complicated regulations. As these regulations grow more complex, companies and MS4s are trying to solve how to best meet them t…
Stormwater Compliance Challenges
Understanding What is Required There are many components to effective compliance programs, and they all
work together.Regulations, Permitting, Documents, Timing, Processes, Ongoing Documentation, Training, and more...Example: Consent DecreeTechnology is NeededAll Documents, Permits, Maps in One PlaceRequired TrainingMaps History24/7 Accessibility
Ever Changing Requirements Multiple Regulations Impacting Different OperationsStormwaterAir QualitySafetyTrainingInspectionsLack of Someone Specializing in Stormwater RegulationsProper ResourcesProper TrainingExperienceExample: Inspection Forms and Plans
Training Owners and Management PersonnelAll Individuals Involved with Everyday OperationsCompany ProcessesExample: Action Items
Proper Tools to Obtain Compliance Wated Time and ResourcesLack of understanding as to which tools are needed to achieve company goals Impacts Management and OversightExample: Inspection Specific Apps and Products Not Specific to Stormwate…
"I've been doing this for 40 years and I've never had to have a SWPPP before. Why do I need one now?"
People ask me this question a lot. In fact, people ask me this question way too often. It's time we put the subject to rest. SWPPPs aren't new and they aren't going anywhere. This may be the first time you've heard of it, but it certainly won't be the last.
What is a SWPPP?
SWPPP stands for Stormwater Pollution Prevention Plan. The name pretty much says it all. A SWPPP is a plan that must be in place on all construction and industrial production sites that disturb more than 1 acre of land. They are also required for a lot of projects that disturb less than 1 acre of land.
The SWPPP tells the EPA, your state, and your municipal separate storm sewer system (MS4) exactly how you plan on keeping sediment, debris, fuels and oils, paint, concrete, and any other pollutant you might generate out of the storm drains, lakes, rivers, streams, oceans, and e…