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 my first post in this series we discussed the importance of making a corporate commitment to meeting stormwater regulatory expectations. We also noted that you can’t make a commitment unless you understand what the expectations are and then provide your people the tools needed to get the job done.
Which brings us to the second ingredient for success, which is the most important tool a company can provide: a standardized stormwater management system that works on all projects, in any jurisdiction, every time.
The truth: It won’t succeed if it’s not standardized.
The EPA NPDES Stormwater Construction General Permit is the foundation for all state stormwater permits. While there are some minor regulatory differences from state to state, if your standardized program is well-designed to meet the EPA requirements, it will work well-enough in any jurisdiction. The system must consistently yield regulatory compliance when it is fully implemented.
The importance of having a company-wide standard methodology for stormwater compliance cannot be understated. Effective training depends on it. With the right system in place, adequate SWPPP Administrator training can take only hours. Learning the stormwater regulations can take months, or longer. Leaving stormwater program development up to each project is a big mistake and will cost your company on every project. It will result in hit-or-miss compliance and expose the company to risks that are easily avoidable.
Performance measurement and therefore the ability to hold people accountable, two key ingredients for success, also hinge on having a standardized, systematic management system. If you have the right stormwater management system that yields compliance when implemented it doesn’t take a stormwater expert or a regulator to measure performance. Any number of people in your organization can measure system implementation with very little training. Course corrections on system failures are easier and cheaper to make than risky compliance failures in the field.
To achieve sustained, cost-effective success, companies must commit to implementing a standardized stormwater management system first. Even an imperfect system is better than none but it would be well worth the cost to hire a skilled consultant to help do it right the first time.
In the next post in this series, we’ll talk about fast, easy and effective enabling systems that will give even an inexperienced employee the skills and tools they need to achieve success.
You can see all of the posts in the Recipe for Compliance Program Success series here.