May is National Safety Month and my ongoing onsite mantra of “environmental compliance is the new safety” came to mind. I use this phrase with clients, contractors and subcontractors when I get the usual retort of “we’ve been doing it this way since before you were born.” I must look young for my age, but the fact that someone is unwilling to change a methodology or process simply because that’s the way they’ve been doing it, apparently for nearly 5 decades, is a disservice to the trade, the construction industry, the environment, and their client. When OSHA was created in 1971 safety regulations began a multi-decade push to becoming an ingrained and second nature effort on any construction project. I can just imagine the old timer foreman in 1980 saying to a safety inspector “we’ve been hanging upside down from that scaffolding to paint the under side of window trim without a harness for decades, we ain’t starting now.” Fast forward to today, fall protection is a requirement and not considered optional by workers as they have been brought through their apprenticeships with the process as just a part of the job.
Now let’s consider storm water discharge and water quality protection regulations. Construction projects have been required to implement Best Management Practices (BMPs) for water quality protection since the early 90’s. These requirements are typically still seen as an unnecessary cost and just a way for regulators to make a project unprofitable. This perspective is unfortunate, but a somewhat justified view when the regulators and the sediment and erosion control professionals do not do their job correctly. Storm water quality discharge protection is easy to do, if you have the right mindset and the right appreciation for the outcome. The construction industry is still exhibiting the regulatory growing pains of implementing appropriate environmental protection measures on jobsites equitably across the industry, and there are plenty of “qualified professionals” out there assisting them in doing so inefficiently.
As a Qualified SWPPP Developer and Practitioner (QSD/QSP) in the State of California, and a Certified Professional in Erosion and Sediment Control (CPESC), I have observed ineffective and inefficiencies, and strive to make compliance an effective project solution by using a rationally minded approach. Environmental protection is no different than safety when it comes to defining the process if you think about the outcome as the goal. “Every worker goes home every night with all their fingers and toes” is a great way of thinking about what the outcome shall be for a safety program. Likewise, for the environmental perspective, “My actions shall not create a degradation to my neighbors, the flora and fauna downstream of my jobsite” will reframe what the outcome shall be. How you execute that goal is where a truly experienced partner in the process comes in. What I bring to my projects in any Storm Water Pollution Prevention Plan that I write and/or oversee is that any labor or material employed will actually have a benefit, rather than just be window dressing. You’ll never see a fiber roll on the crest of a hill, a gravel bag berm along the toe of a brick wall, a row of sand bags installed 6 inches below the sidewalk that forms a elevational grade break at the project perimeter, or a silt fence hanging on a chain link fence (see photo). Why do we see these on jobsites across the country? These are examples of looking at the permit requirements without thinking through to outcomes, “I must have a BMP at the project boundary because that’s what we always do.” Or worse, there are no BMPs for water quality protection on a site at all. Both conditions are a detriment to the project, one financial and the other negligent.
The improper installation of a BMP not only wastes money, but it can draw a regulator’s eye to your project more than not having a BMP in place.
When you partner with a rational approach minded environmental consultant, profitability can be paired with environmental protection. Just like ensuring your employees are able to go home in one piece each night and be able to return the next day is a rational minded approach to safely staffing a project. If you are interested in discussing how your construction project’s environmental compliance can be maximized for efficiency and practicality, please let me know by email at firstname.lastname@example.org and I’ll come hang upside down from the scaffolding and paint some trim with you (both of us wearing the proper safety harness for the job, of course!).