SWPPP Documentation: A Contractor's Achilles Heel
There is an arduous dance Contractors, Operators and Permittees perform to pursue compliance with the U.S. Environmental Protection Agency’s (EPA) stormwater quality regulations. General Contractors and project owners balance field activities to make stormwater pollution prevention a reality with updating their stormwater pollution prevention plan (SWPPP, SWMP, SWP3) documentation. Small Operators may not be aware of construction general permit requirements or too small to dedicate resources and time to compliance activities.
A new construction site may be the epitome of implementation perfection - every stake placed in the right increment and every waste bin covered. But, if the SWPPP does not match site conditions or demonstrate ongoing updates in line with the Living Document Rule, it will not be enough to avoid potential fines or notices of violations when the regulating agency arrives. This seems like a counterintuitive response, almost hypocritical.
The most common non – compliance findings identified by the EPA involve the paperwork, or lack of paperwork, instead of violations in the field. These issues include:
No Permit or Notice of Intent
No Sediment and Erosion Control Drawings
No Inspection Records
No Amendments to the SWPPP/SWMP/SWP3 or drawings, if appropriate
The associated penalties and fines for administrative or civil judicial penalties can be high – as high as $100,000 per day a violation occurs for existing offenders who knowingly commit a violation. That’s a lot of dough and does not include the cost the Operator will bear in true dollars spent in labor costs and legal fees to fix those issues.
CAN I AVOID THESE PITFALLS?
Yes, yes you can. No one enjoys paperwork. Especially when you’re in the middle of building the next award – winning structure. But it is necessary to demonstrate your attention to SWPPP compliance.
We are all pretty attached to our smartphones and laptops. Fortunately, the cloud computing and technology industry is producing a ton of innovative and easy to use tools to help you help yourself. The saying, ‘There’s an app for that’ is truer today than imaginable.
Transferring your stormwater compliance management activities to an electronic platform allows you and all stakeholders to see and interact with various reports, forms, tasks and documentation in one location. Automating certain tasks such as weather monitoring and maintenance reminders will trigger your site personnel to act promptly and proactively. Use a cloud – based platform to house your SWPPP, permit and erosion control drawings with integrated tools to allow you to update these documents live.
Comply26 is one leaf on the branch of the growing cloud computing industry. We focus our efforts to automate actions where possible and build various check points to prompt each participant to complete the full regulatory circle. Technology is as powerful as you allow. Adopting technology-based tools into your work environment and culture may allow you to avoid some of the seemingly easily - avoided violations above and ultimately reduce your administrative work load.
With Comply26 you will have a team of doers with actual field experience performing inspections, installing controls, and fulfilling EPA NPDES requirements to onboard you to the Comply26 system. By implementing our standardized process backed by automated notifications and easy updating, you will minimize your exposure to liability and fines. Additionally, you can brag to your friends that you are doing your part to keep public waters clean and free of sediment and pollutants.