EPA Proposes Changes in New MSGP

June 22, 2020
By Brian Schefke

In March, the EPA released its final proposed version of the Multi-Sector General Permit (MSGP) that will replace the 2015 version currently in force. The MSGP authorizes stormwater discharges in areas where the EPA is the permitting authority, e.g., areas not covered by a state general permit. The comment period for the proposed permit ended June 1, and the EPA will issue the final permit later this year.

In response to a National Research Council study on improving the MSGP, the EPA has proposed a number of changes to the permit in the new version. The most substantial are summarized …

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Violations of the Clean Water Act in Washington in 2019

June 2, 2020
By Jenny Ma

Over the past several years, regulatory authorities and nonprofits have increased their watch over stormwater compliance. Freer Consulting routinely monitors records for the state of Washington from the Region 10 office of the Environmental Protection Agency for Notices of Intent (NOI) to Sue under the Clean Water Act. In 2019, the EPA received 21 NOIs for Washington businesses and individuals.

Of these 21 NOIs, the top five categories were:

  • Discharge without a permit: 11 – 52% of NOIs
  • Numeric effluent violations (e.g. facility is discharging with pH levels outside of permitted limits): 11 – 52% of NOIs
  • Failure to prepare

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King County Stormwater Violations Trend

May 8, 2020
By Jenny Ma

This year, a new permit for Industrial Stormwater General Permit (ISGP) for the state of Washington went into effect. Now is a great time to look at how permit holders in King County did over the 2015-2019 period regarding stormwater violations.

Data was collected from the Department of Ecology looking at all industrial stormwater violations reported in each year for King County during the 2015-2019 permit period.

Over the permit period, the top three violations have been benchmark exceedances, monitoring violations, and reporting violations.

  • Benchmark exceedances (e.g. a stormwater sample contained lead that was over the 64.6 µg/L limit) have

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Using ISO 14001 to Simplify GRESB Reporting

May 4, 2020
By Aaron Schlossman

Completing Global Real Estate Sustainability Benchmark (GRESB) reports is a complex, resource-intensive process for any business, whether it’s are establishing benchmarks for the first time or working towards well-specified goals. GRESB has successfully streamlined the reporting process, but data collection, management, and verification still pose obstacles during the annual reporting cycle.

GRESB complexity comes from the same source as its elegance. The thorough consolidation of external frameworks into one reporting tool, packaged into a seamless interface, takes much of the pain out of presenting data from your year. Often, we find that the remaining challenges stem from structuring operations to …

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COVID-19 and CLIA Expedited Certification

April 24, 2020
By Carrie Salters

With COVID-19 clinical laboratory testing continuing to ramp up throughout the United States and worldwide, Clinical Laboratory Improvement Amendments (CLIA) applications for registration are continuing to increase. In response to the pandemic, the federal government is taking unprecedented action to ensure laboratories in the United States wishing to test for COVID-19 are expedited through the CLIA certificate application process.

On March 26, 2020, the Department of Health & Human Services Centers for Medicare and Medicaid Services (CMS) Center for Clinical Standards and Quality/Survey & Certification Group issued a memorandum reference number QSO-20-21-CLIA regarding CLIA Laboratory Guidance During COVID-19 Public Health …

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Remote Stormwater Regulatory Compliance

April 10, 2020
By Brian Schefke

In this time of social distancing due to the Covid-19 pandemic, it’s challenging to comply with regulatory requirements due to disruptions in business operations or lowered staff availability. Despite these challenges, there isn’t a legal mechanism that relieves businesses of their duty of regulatory compliance. The pandemic and efforts to fight it continue, yet rain will still fall and stormwater must continue to be managed to reduce pollutants entering our waters.

Many businesses have shifted, at least in the short term, to remote work wherever possible. There’s a number of business functions that you can do remotely, and stormwater regulatory …

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USCG Crackdown on TPO Inspections of Quality Management Systems

April 6, 2020
By Carrie Salters

On March 31, 2020, the United States Coast Guard (USCG) updated CG-CVC Mission Management System Work Instructions CVC-WI-005(2) Request For Recognized Organization Internal Quality Management System Review – “Quality Case” to inform USCG Marine Inspectors to “evaluate situations where objective evidence indicates that a potential failure of a Recognized Organization (RO) or a Third Party Organization (TPO) under 46 CFR Subchapter M Quality Management System (QMS) resulted in the failure to adequately perform delegated functions under mandatory IMO instruments or national legislation and regulations on behalf of the Coast Guard.”

It further states that “delegated functions” is defined as synonymous …

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Benefits of R2 Certified Recycling

March 30, 2020
By Freer Consulting

Electronic waste is all too often making its way into local landfills or being exported to countries where it is improperly disposed of, posing a significant threat to the local people and the environment in general. 

Responsible Recycling Practices Standard, known as R2, was facilitated by the EPA and developed by recycling stakeholders to promote and assess responsible practices for electronic recyclers. 

Getting certified with R2 requires implementation of an environmental health and safety management system, (EHS). The EHS serves a purpose of affecting worker health and safety, security, the environment, and the downstream management of end-of-life electronic material and

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Changes to the Washington ISGP: Are You in Compliance?

March 27, 2020
By Brian Schefke

The new Industrial Stormwater General Permit (ISGP) for the state of Washington went into effect on January 1, 2020 and contains many changes from the 2015 permit that affect both current permittees and businesses that were previously not covered by the permit. Major changes include:

  • When applying for coverage, applicants must identify their industrial category using North American Industry Classification System (NAICS) codes instead of Standard Industry Classification (SIC) codes.
  • Two new industrial categories are required to obtain permit coverage:
    • Construction; Transportation; Mining; and Forest Machinery and Equipment Rental and Leasing (NAICS codes 53241x)
    • Marine Construction (code ECY003)
  • The date

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Remote Compliance Support for Essential Operations

March 25, 2020
By Mairead Roden

Last night, Governor Inslee issued a “Stay Home, Stay Healthy” order, which requires Washingtonians to stay home for at least the next two weeks to flatten the curve of the COVID19 pandemic and keep our healthcare system functioning. This order is crucial for the health of our community. It also highlights just how many sectors are considered essential to maintain the critical infrastructure of our state and country.

At Freer Consulting, we have served clients in these essential sectors, both in person and remote, since 1998 though engineering, certification, compliance, and other services. As an essential business ourselves, we continue …

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