In this series of posts, we’re talking about the Recipe for Compliance Program Success. You can see all of the “ingredients” in this series here.
In the first and second posts of this series outlining SRM’s recipe for an effective stormwater compliance program, we talked about first making a corporate commitment to compliance and then setting up a standardized stormwater management system, two critical ingredients for meeting your company compliance goals.
Once this is done you’re ready for the third ingredient: enabling employees to deliver the results in the field.
Proper training and efficient recordkeeping systems are the two most important enabling systems.
Most stormwater training focuses on general permit requirements and how to perform an inspection. Not a waste of time but this information is usually quickly forgotten when the trainee returns to the many other demands of the jobsite. Students should leave training with a system they can immediately implement in the field and have success. Stormwater training should include some background about the regulations such as general expectations, potential penalties for non-compliance, how to tell if controls are working, etc. The primary focus of training, however, should be on how to implement the company’s standard compliance program and why doing so is important to achieving company goals.
In the last post in this series, we talked about how a well-designed stormwater management program will yield regulatory compliance when fully implemented. It stands to reason that training to enable full program implementation will therefore yield acceptable permit compliance. Ideally, the trainee should leave with a step-by-step set of instructions on how to implement each aspect of the company compliance program and a clear understanding of company performance expectations.
Despite training, SWPPP Administrators historically struggle with the amount of recordkeeping required by the stormwater regulations. Failing to properly keep those records is a serious risk to companies. At a minimum, every project should have a standardized binder system that includes tabs for every major element of the standard management system. Supervisors can easily be trained to regularly review binders to assure they contain the required records.
Even better are some recently available digital or paperless SWPPP recordkeeping systems. More advanced systems allow the SWPPP Administrator to perform all required inspection and recordkeeping functions such as site map updates, daily logs, etc., without using any paper forms. These digital records can be reviewed by authorized personnel from any internet accessible location. But beware, while good digital systems can save significant time and money, bad ones can cost both, and expose you to enforcement.
Once you have a standard stormwater management system in place and people trained to use it properly you can move on to the next ingredient in my recipe for success, performance measurement. In the next post, we’ll talk about the many ways stormwater program performance can be measured and acted upon to encourage continuous improvement and achieve company compliance goals.
You can see all of the posts in the Recipe for Compliance Program Success series here.