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post #1 of Old 06-28-2018, 08:55 AM Thread Starter
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Exclamation Clean Water Act - Waste Water

I was bidding a $10k plus job yesterday and the question popped up about waste water. I am located in Houston, Texas and run a Houston Pressure Washing Company. The clean water act is serious business around here. Any runoff that contains any hazardous material that ends up in the storm drains will cost you big time.

So how do we avoid this? Set up water barriers.... use a water recovery system (costly).

Some projects require more precautions for exampling when washing the siding of a building you will not have to use a full-blown recovery system. When cleaning a gas station you will need to use a system.

I am sure you can figure out how to get around buying an expensive setup.

Please do not talk this as the rules to follow.

Who Is Responsible?

It is up to the cleaning professional recommending exterior cleaning solutions to fully understand the steps they or a hired professional must take to avoid violating the Clean Water Act or theyíll put the buildingís property owner at risk of serious fines.

Thatís right, contrary to popular belief, the responsibility of water reclamation when cleaning property exteriors is not in the hands of the cleaning professional or the pressure washing company Ö it rests with the property owner.

Property owners can face fines of up to $50,000 a day if the water used in a pressure washing project contains dangerous chemicals or is allowed to contaminate the storm drain system.

As suggested, the EPA is holding property owners accountable at an unprecedented rate.

For example, in 2012, the EPA levied a record number $252 million in fines collected from civil and criminal penalties related to water contamination.

That number far exceeds the $168 million collected in 2011.

Plus, the U.S. Supreme Court further empowered the EPA earlier this year by validating the EPAís strict interpretation of the Clean Water Act.

In the case of Decker vs. Northwest Environmental Defense Center, the Supreme Court voted 6 to 1 to uphold the EPAís interpretation of its own regulations.

So how can cleaning professionals steer clear of trouble and keep their property owner free from fines when completing exterior cleaning projects?

I recommend the following set of questions that facility managers must ask when tackling power washing projects on their own or with a power washing professional.

Q: Are any cleaning agents or products being used? If so, are they biodegradable or environmentally friendly?

A: Some projects donít require cleaning agents to get the job done, but many do.

It is important to know what agents are being used.

Caustic chemicals and bleach are to be avoided.

Look for companies that use chemicals that are citric based and therefore biodegradable and environment friendly.

Q: Do we have the equipment necessary to collect and clean the runoff wastewater after the cleaning process? How are we making sure to prevent this wastewater from entering the environment?

A: A service provider with a water reclamation system that captures and re-uses wastewater will greatly minimize the risk of EPA violation or issues.

If a power washing provider is being used for the project, ask how they handle water reclamation.

If they donít reuse it, make sure they are disposing of it in a way that is EPA compliant.*

This water run-off issue is why some facilities rely on a power washing expert to complete power washing projects.

While it is possible to complete do-it-yourself power washing projects, it is incredibly difficult to avoid violating the Clean Water Actís runoff policy.

Q: Do you or the service provider have adequate insurance coverage, including pollution coverage or waste water generation coverage?

Few cleaning professionals, and quite honestly, few power washing providers, possess adequate insurance coverage to avoid the risk of Clean Water Act fines.

Many individuals and companies with the best intentions could still be susceptible to a mishap with waste water reclamation.

Cleaning professionals must make sure they or the company they hire has enough insurance coverage in case of a mishap.

Q: If you are using a power washing company, are the service providerís employees contract labor or W2 with workers compensation coverage employees?

A: Pressure washing can be dangerous, and knowing whether or not the laborers working on the property are covered is important.

According to the National Electronic Injury Surveillance System, there were an estimated 5,334 pressure washer-related injuries treated in hospital emergency departments in 2012.

Donít assume an injury canít happen during the job.

Q: If you are using a power washing company, has the company or any of its customers ever been fined as a result of cleaning services?

A: Itís not enough just to ask for references; cleaning professionals need to discover whether or not the company or its clients have been a target of the EPA.

Knowing a companyís history doesnít ensure that something wonít go wrong on your job, but at least it gives cleaning professionals a good indication of the companyís EPA compliance.

Once satisfied that the pressure washing company uses EPA compliant practices, be sure to have a system in place to verify that the approved equipment is being utilized whenever they are doing jobs.

Ask to see the water reclamation hardware and ensure that itís working properly.

Ask a question if something doesnít look right, and occasionally run spot checks when jobs are being performed to make sure the company has delivered on its promise to keep you out of trouble with the EPA.
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