Stormwater Minute: 10 Steps to Implementing A Stormwater Program

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10 Steps to Implementing and Maintaining an Environmental Compliance Stormwater Program
  1. Know the rules & regulations for your City, County, State and Federal. Be aware that different soil types can affect stormwater in different ways, and there are different limitations on what is an acceptable concentration of sediment, heavy metals or other contaminants for different bodies of water. Many State rules and limitations are stricter than the Federal regulations.
  2. Review your site and document findings, both good and bad so you can correct and prevent any potential issues. Walk your site to create and manage an inspection checklist for review or potential submission to State or Federal agencies. Evaluate neighboring sites where they are adjacent to yours, to determine if they will add to issues on your site from stormwater runoff or other contamination means.
  3. Create your SWPPP (Storm Water Pollution Prevention Plan) and submit your NOI (Notice of Intent) to the permitting authorities. Manage your SWPPP, updating any changes, issues, and tracking inspection reports. You should also have included all emergency response documents such as what is the procedure if there is a spill or what to do in the case of a BMP failing, etc.
  4. Meet with your team and anyone onsite to make they are aware of the SWPPP BMPs and set your expectations. Anyone onsite could see issues and report them to reduce potential larger leaks or contamination. Discuss non-compliance and ramifications, so everyone is aware and can respond accordingly. Simplify as much as possible to make it easy for everyone to comply and assist with compliance.
  5. Review your procedures and BMPs to see if there is a better or easier way to be in compliance. Look for simpler or more effective BMPs and be sure to update your SWPPP upon implementation to keep your records up to date.
  6. Be sure to follow any sampling of stormwater runoff as required by your County, State or Federal agencies.
  7. Maintain good housekeeping and preventative measures. Make sure you have sufficient secondary containment in case of a leak, spill kits in case of a spill and maintain BMPs, as well as clean up any debris to prevent potential issues.
  8. Keep all of your potential contaminants on your own site and minimize any runoff to any adjacent properties or storm drains. In the case of a construction site, be sure to stabilize the site as you go as it will be easier to maintain.
  9. Maintain records and take pictures if possible to show issues and resolutions. It is better to have too much documentation rather than not enough in case of an audit or incident.
  10. If you are on a construction site and have finished the job, file your NOT (Notice of Termination), tidy up and leave the site being sure to remove all temporary BMPs and debris that needs to be disposed of. If not, be sure to constantly maintain your SWPPP and file any annual or quarterly reports necessary for compliance.

That is this month’s Stormwater Minute!

Brad Kemp – CISEC, is a Regional Sales Manager for UltraTech International, Inc. and the in-house Stormwater Management and Erosion Control expert (aka The Stormwater Guy). For more information on UltraTech’s expansive line of compliance products please visit www.StormwaterProducts.com brad

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GHS Compliance Kit – Free Download

We’ve been talking about the GHS for the past three posts. Now that we’ve learned a little more about what it is, why it’s needed and what needs to be done to comply with it it’s time to actually start making the changes and doing the training that is required.

 

Fortunately, help is available. I’ve located a site for you where you can download a complete GHS Compliance kit that gives you everything you need.
It contains:
GHS Labels
GHS Poster
GHS PowerPoint presentation for training on the GHS
GHS Purple book that contains links for downloading the following pdfs:

The Free GHS Compliance Kit is available through http://www.ghskit.com/
You’ll have to sign up and they’ll send you a link to download it.


“Small Entity Compliance Guide for the Respiratory Protection Standard”

OSHA has just published a free 124 page document entitled “Small Entity Compliance Guide for the Respiratory Protection Standard

The document is “intended to help small businesses comply with the Occupational Safety and Health Administration’s (OSHA) Respiratory Protection Standard… OSHA’s goal for this

document is to provide small entities with a comprehensive step-by-step guide complete with checklists and commonly asked questions that will aid both employees and employers in small businesses with a better understanding of OSHA’s respiratory protection standard.”

 

Its’ goal is a plain English guide to help small and medium businesses comply with the OSHA standard.

It also contains a comprehensive set of definitions to help clear up any confusion about terminology, clear and revised Assigned Protection Factors (APFs) as well as updated Maximum Use Concentrations (MUCs).

 

Especially helpful are the numerous checklists scattered throughout the document which can help users figure out which respirator is needed, checklists to make sure that all necessary steps have been taken, checklists to make sure that the required documentation is there and much, much more.

It is well illustrated to remove any doubt as to the nature of the type of respirator needed and contains all the necessary documents such as a copy of the medical evaluation form and more.

 

A definite “must have” document to download and keep on file.


Psychology vs. Enforcement… What works?

There as long been a debate going when it comes to safety compliance as to whether it is best to motivate people into compliance using psychology or enforcement. In other words what works better, showing people the reasons behind the rules and explaining the fact that it’s for their own and everyone else’s good or simply telling them “do it or else!”

We’ve talked in the past in this blog about sending people with paid when a safety violation occurs rather than sending them home without pay as a way to drive home the point that it isn’t about punishing people into compliance but rather as a means to get them to “own” safety for what it is.

So what is best? Does psychology work better or does enforcement?

The question as phrased is misleading for the simple reason that everyone is different. I used to know how to raise children till I had one of my own. Then, thinking that I had figured out what worked and what didn’t, I eagerly looked forward to the birth of the second child only to find out that what worked for the first child did nothing whatsoever for the second. Every parents has been there. No two kids are alike. Where beatings won’t affect change in the one, a simple look of reproach will send the other one into tears.

Adults are no different (especially us men who are simply grown up little boys as we all know). What works for one will help not one bit in motivating the other to compliance.

Take good eating for example. Some of us have only to read about how a healthy diet affects our bodies and how an unhealthy one is slowly killing us and we will make drastic changes. At the same time we all know the guy who was 40 lbs overweight, who had a heart attack, who swore that he would change but who, 6 months later is still eating fast food and sucking on soda by the gallons. Why is it that the one has only to read about it to change while even severe painful consequences won’t move the second?

Psychologist will no doubt have all kinds of explanations for the behavior of the second but ultimately, in the workplace it doesn’t matter. Both psychology and enforcement are going to have to be used because people all respond differently.

And if neither work than it’s probably time to replace that employee.


Download the new OSHA “At-A-Glance”

What are the responsibilities of OSHA? What are their rights? What are your rights with respect to OSHA inspectors? What does an OSHA inspection look like?

A new publications OSHA at-a-glance can answer all these questions for you and for your employees. It isn’t a long, daunting manual, it’s a short 3-page pdf that you can download and that provides, like it’s name says, a quick glance at who OSHA is and what they do.

Here, for example, from page 1 is the rights and Responsibilities of the employer with respect to OSHA:

Employers must:

Follow all relevant OSHA safety and health standards.

Find and correct safety and health hazards.

Inform employees about chemical hazards through training, labels, alarms, color-coded systems, chemical information sheets and other methods.

Notify OSHA within 8 hours of a workplace fatality or when three or more workers are hospitalized (1-800-321-OSHA [6742]).

Provide required personal protective equipment at no cost to workers.*

Keep accurate records of work-related injuries and illnesses.

Post OSHA citations, injury and illness summary data, and the OSHA “Job Safety and Health – It’s The Law” poster in the workplace where workers will see them.

Not discriminate or retaliate against any worker for using their rights under the law.

 

Download it here.


The “Why” of safety is important as well

One of the elements that is missing in many safety programs is the “why” behind the rule. The safety program may outline the need for Personal Protective Equipment as well as procedures for safety in the workplace but in order to get employees to buy into the safety culture necessary around the job site, it is important to let them know why it is important as well.

It is one thing to know that they are required to wear a hard hat in select areas but unless the employees clearly understand why it is necessary they will be tempted to remove it as soon as it gets a little hot and uncomfortable.

One of the top hits on the internet with regards to safety has to do with the image of a man’s genitals after he took a fall while wearing a loose fitting harness. It is extremely graphic but I get a lot of requests for the image because safety professionals want to post it for their employees to see so that they’ll understand why it is so important to wear the fall protection harness correctly. The truth is that wearing it loosely is a whole lot more comfortable, especially on hot days and when there is a lot of climbing around to do. One look at the image, however, is usually enough to solve the problem of loosely fitted harnesses.

While no one likes to go looking for gory photos of what can happen if safety precautions aren’t followed, they do seem to be a fast and effective way to drive home the point.

When, as an employee, I understand that safety isn’t just about keeping OSHA and L&I off the backs of my employers and get that it’s intended for my own protection; when I see what can happen if and when safety measures aren’t followed and PPE isn’t worn properly, I am much more likely to follow procedures and wear the PPE when I should. It’s why we sit down with children and try to explain to them why they shouldn’t run into the street without looking. It’s why we try to explain to teenagers why wearing a seatbelt is so important (DUI videos, for example, show some pretty graphic stuff in order to scare those arrested for DUI offense).

While your employees may not be teenagers and small children, human nature being what it is many of us still get attitudes when “bossed around”. Being told to follow rules and wear PPE usually don’t produce compliance, at least not to the level that we need to see in the workplace, unless it is accompanied with a clear explanation of the reasons behind the rules and procedures.

By the way… to view the results of a loosely fitted harness after a fall, click here.


Help from OSHA in New Residential Construction Standard

Back in December, OSHA issued a new directive concerning residential construction fall protection (See “Compliance Guidance for Residential Construction“) in an attempt to reduce the number of falls from roof in residential construction. Deaths from falls remain the leading cause of death in that line of work.

Today, April 8th, OSHA has issued a new document entitled “Fall Protection in Residential Construction” that is intended, not only to tell workers that they must in fact comply or be fined, but also to try to help them find workable solutions to make compliance possible.

This 22 page document outlines various methods and practices that can help reduce the number of falls in residential construction.

Let’s take roof trusses as an example. In new residential construction, the easiest and sometimes the only way to install these trusses is to have one person at the top of the roof and one person at the ridgeline, each nailing in their side of the truss. The problem is that the worker at the ridgeline is most often straddling and/or walking along the outside wall and extremely susceptible to falls. OSHA suggests a simple and practical solution in the form of a bracket scaffold (see page 5 of the document). “A bracket scaffold can be placed on the interior or exterior of a structure. The scaffold can provide a stable working platform. When bracket scaffolds are used on the interior of the structure, the exterior wall can limit employee exposures to fall hazards.”

OSHA includes images to help illustrate the suggested solutions. Thus, in the case of bracket scaffolds they post the following images:


If you are working in residential construction (or even if you do work on your own home from time to time), you owe it to yourself and/or to your workers to take some time studying this document.

It makes compliance easy without adding a huge expense. The life you save might be your own.


Why OSHA matters (even if you are just a 2 man operation)

There seems to be a mentality, among many small businesses, that OSHA and LNI regulations really only apply to the medium or large size business. After all, as a 2-man operation doing residential window washing or roofing, the odds of an inspector even seeing you, much less citing you seem to be about the same as the odds of winning the lottery. These business owners tend to abide by the mentality that if they can get away without getting caught, they don’t have to worry about abiding by the regs. It’s more or less the way a lot of us function with respect to speeding; as long as we don’t get caught we feel we ought to be able to go as fast as we like.

The problem with that mentality is that it’s the ugly step child of the thinking that says that others may get injured if they don’t do it the right way but that isn’t true of me because I’m more agile, smarter (how twisted is that?), faster, more aware or whatever other lie we try to tell ourselves to justify not taking the time to do it safely. It’s the same thinking that allows teens (and a lot of adults too) to understand that it’s completely unsafe to text while driving while texting while driving themselves.

The other problem with this thinking is the potential for catastrophic loss. In a large business, the loss of only employee because of injury, while costly and inconvenient, isn’t necessarily going to affect the company as a whole all that much (for example, one employee out of 100 is only a 1% loss in personnel). For a two-man operation, however, the loss of one employee could make the difference between staying in business and having to declare bankruptcy (few companies can sustain a 50% loss in productivity and stay in business for long).

Small business owners need to understand that the cost of compliance is like the cost of an oil change; you can pay a little now or pay a whole lot more later when everything blows up. Small business owners need to retrain themselves to think of OSHA and LNI as expert who have found ways to help you stay in business rather than “the enforcer” that they try to keep away from.

It could, after all, make the difference between staying in business or folding shop.


New 3M Noise Indicator makes compliance simple and inexpensive

 

Want to monitor noise levels in your facility without paying an arm and a leg? The new 3M noise indicator might be the answer. At a price point under $40.00, this is a very inexpensive solution.

It’s simple… as long as the light is flashing green the noise level is under 85 dBA and you’re in compliance. As soon as the noise level climbs over 85 dBA, the light starts flashing red.

It’s small, very small about the size of a pocket of matches (1.5″ x 2″) and clips right onto your lapel. It also has up to 200 hours of run time on a full charge. When the it needs to be recharged, simply plug it into a computer with a USB cord (sold separately for under $5.00).

To find out more about this noise indicator, check it out here (You can download an instruction sheet and a cut sheet in pdf format by clicking on the “Additional Info” tabs at the bottom of the page)