For the Record

About the author: Jennifer Hildebrand, CPESC, CPSWQ, CESSWI, CISEC, is national compliance manager for Weis Builders Inc. Hildebrand can be reached by e-mail at [email protected].

In the day and age of multi-dimension lawsuits, what one does is not always as important as what one writes down. Construction has not changed dramatically over the last 100 years, but the business climate that surrounds construction has. In addition, the regulations and environmental guidelines that exist on each job site today are very different from those of 50 years ago.

Because of these changes, we need to be very diligent about how we document activities of compliance on a construction site. This includes records, daily observations and photo documentation. Whatever requirements indicate for inspections and documentation, remember it is a critical component of “telling your story.” The records become critical elements that indicate a record of all activities surrounding a compliance strategy. Oftentimes the level of detail one documents becomes the very thing that saves him or her in a situation where environmental compliance is in question.

First, decide what checklist or document to utilize for records. There are several thousand free samples online to review and revise. This is an important detail because it increases the quality control for the overall project, meaning that no matter who is conducting the inspection, the records will be similar. This also means that the categories of inspection will be similar and the recorded details should align. The permit that indicates one is authorized to discharge storm water will also most likely indicate what elements need documenting, so approve the form with these details in mind. In addition, determine before the project begins how often to inspect. The federal rule is clear about inspection frequency, so make sure you understand local and state documentation requirements and integrate them into your decision.

Second, determine what level of monitoring and sampling the project requires. For example, if required to provide water quality sampling reports, understand what this means and how to initiate and maintain these records. If this is not a requirement for a project, consider it anyway as a practice for well-documented activities. There are numerous levels of sampling practices; the critical element remains selecting a practice that works for a specific level of construction site management. One must also determine the protocol for what processes exist when levels of acceptable discharges are becoming close to the limits. What to do if an extreme event occurs, and what emergency measures exist when this type of situation exists? These types of contingency planning measures are often the difference between a well-managed and poorly managed site.

Finally, although not a federal requirement, integrating a photo documentation element into inspection protocol is solid advice. Some projects may warrant daily pictures; some may warrant pictures at the time of major grading activities. Pictures should be managed and filed with the same intensity of written documentation. Wherever possible, full integration produces the best record.

In an age where there are many effective electronic inspection programs on the market, there is no need to allow inspection and documentation to be a burden on a construction site. Doing it right and effectively is the best insurance you can buy for limiting risk of noncompliance on a construction site.

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About the Author

Jennifer Hildebrand