| Containment of wash down water for portable restrooms issue grows |
New regulation/legislation has made portable restroom contracting a bit more of a challenge. The Federal law effecting
primarily portable restroom contractors in southern California is geared to capture the water used to clean the walls and
floors of the portable restroom while it is being cleaned. There has been no concern expressed about containing what is in
the actual portable restroom tank. There does not appear to be sizing issues such as how much water does the containment
system have to capture. All that is reveled is portable restrooms on construction sites require a method of keeping the wash
down water from making contact with the dirt. What is interesting is there are no stipulations when the portable restroom is
washed down in the street such in the case of several types of special events.
primarily portable restroom contractors in southern California is geared to capture the water used to clean the walls and
floors of the portable restroom while it is being cleaned. There has been no concern expressed about containing what is in
the actual portable restroom tank. There does not appear to be sizing issues such as how much water does the containment
system have to capture. All that is reveled is portable restrooms on construction sites require a method of keeping the wash
down water from making contact with the dirt. What is interesting is there are no stipulations when the portable restroom is
washed down in the street such in the case of several types of special events.
The federally adopted program is called SWPPP (Storm Water Pollution
Prevention Plan) and is an effort by officials to reduce storm-water run
off at construction sites. The regulations fall within the Clean Water Act
and require contractors to submit plans to the EPA, outlining how they
are going to address each component of construction where storm water
run off may be an issue.
Prevention Plan) and is an effort by officials to reduce storm-water run
off at construction sites. The regulations fall within the Clean Water Act
and require contractors to submit plans to the EPA, outlining how they
are going to address each component of construction where storm water
run off may be an issue.
Guidelines for actual containment are few but allow for systems including sand bagging around a portable restroom,
digging out an area directly below the unit and lining with plastic to prevent water
from making contact with dirt. Currently, portable restroom rental contractors have utilized containment trays, that by
design allow a portable restroom to be placed inside. This type of system allows for the wash down water from cleaning to
be captured in a tray, which can be evacuated during a standard service call. Evidence of the regulations first appeared in
San Diego where health officials sent
written notification to contractors and proceeded with enforcement backed with a $27,500.00 violation fine for contractors
declining to comply. Currently it is common place to see the utilization of containment trays throughout the region with
several thousand already in place. The portable restroom industry has developed several ‘BMPS’ (Best Management
Practices) including, plastic liners placed under portable restrooms, sandbag berms placed around the plastic-under-lined
portable restrooms, secondary containment trays that sit in portable restrooms to contain wash down water, industrial
absorbent mats placed under units, absorbent booms placed around units, Standard Operating Procedure documentation
that is included in the SWPPP document per job site, and even, on rare occasion, waivers for exemption that are restricted
to specific, regulated areas such as Tribal Lands. These BMPS vary by region due to topography, proximity of bodies of
water, current degree of water contamination, population, regional office requirements, inventiveness, etc.
Because the Clean Water Act is a national program, every state is included in an EPA Region (there are 10 regions) that
have offices to oversee all NPDES permitting, activities, and administration. The EPA Offices are allowed, if a state
chooses, to pass along their authority to local municipalities as long as the municipality’s requirements are at least as
stringent as those laid out by the federal regulation.
It is important to note, that no one BMP is allowed, by law, to be promoted by the EPA. The EPA is required to encourage
the use of any and all BMPS that fulfill the intent and requirement of the Clean Water Act: no pollutants are to be allowed
into America’s storm drains.
Kathleen Groody, Environmental Specialist of the Construction and Industrial Department in the Storm Water Unit for
California, encourages the industry to “use a variety of BMPS” stating, “be inventive in creating your own solution” for
making restrooms compliant. This approach, she advises, will enable our industry to utilize its expertise regarding portable
toilets, allow us to develop a procedure or product that would benefit the portable restroom industry, and finally, help our
customers, the public at large, and our environment.
digging out an area directly below the unit and lining with plastic to prevent water
from making contact with dirt. Currently, portable restroom rental contractors have utilized containment trays, that by
design allow a portable restroom to be placed inside. This type of system allows for the wash down water from cleaning to
be captured in a tray, which can be evacuated during a standard service call. Evidence of the regulations first appeared in
San Diego where health officials sent
written notification to contractors and proceeded with enforcement backed with a $27,500.00 violation fine for contractors
declining to comply. Currently it is common place to see the utilization of containment trays throughout the region with
several thousand already in place. The portable restroom industry has developed several ‘BMPS’ (Best Management
Practices) including, plastic liners placed under portable restrooms, sandbag berms placed around the plastic-under-lined
portable restrooms, secondary containment trays that sit in portable restrooms to contain wash down water, industrial
absorbent mats placed under units, absorbent booms placed around units, Standard Operating Procedure documentation
that is included in the SWPPP document per job site, and even, on rare occasion, waivers for exemption that are restricted
to specific, regulated areas such as Tribal Lands. These BMPS vary by region due to topography, proximity of bodies of
water, current degree of water contamination, population, regional office requirements, inventiveness, etc.
Because the Clean Water Act is a national program, every state is included in an EPA Region (there are 10 regions) that
have offices to oversee all NPDES permitting, activities, and administration. The EPA Offices are allowed, if a state
chooses, to pass along their authority to local municipalities as long as the municipality’s requirements are at least as
stringent as those laid out by the federal regulation.
It is important to note, that no one BMP is allowed, by law, to be promoted by the EPA. The EPA is required to encourage
the use of any and all BMPS that fulfill the intent and requirement of the Clean Water Act: no pollutants are to be allowed
into America’s storm drains.
Kathleen Groody, Environmental Specialist of the Construction and Industrial Department in the Storm Water Unit for
California, encourages the industry to “use a variety of BMPS” stating, “be inventive in creating your own solution” for
making restrooms compliant. This approach, she advises, will enable our industry to utilize its expertise regarding portable
toilets, allow us to develop a procedure or product that would benefit the portable restroom industry, and finally, help our
customers, the public at large, and our environment.
The Sanitation Journal is a monthly trade publication that caters to the portable restroom industry. Each month thousands
of portable restroom operators utilize information from the Journal to aid in business decisions. Subscribe today and make
sure you never miss an issue.
of portable restroom operators utilize information from the Journal to aid in business decisions. Subscribe today and make
sure you never miss an issue.
The containment of wash down water gathered from cleaning portable
restrooms on construction sites has become an issue that has expanded
outside California borders and is popping up in areas such as New
Jersey, Arizona, Illinois and various locations throughout the states.
Although some locations are being hit with small quantity orders from
residential contractors, firms such as Wal-Mart are taking no chances
and have implemented a plan to require all their construction contractors
to order portable restrooms with the ability to contain wash down water
and keep it from dripping off and onto the ground.
restrooms on construction sites has become an issue that has expanded
outside California borders and is popping up in areas such as New
Jersey, Arizona, Illinois and various locations throughout the states.
Although some locations are being hit with small quantity orders from
residential contractors, firms such as Wal-Mart are taking no chances
and have implemented a plan to require all their construction contractors
to order portable restrooms with the ability to contain wash down water
and keep it from dripping off and onto the ground.
According to Wal-Mart Stores, Corporate Communication Manager,
Christi Gallagher, contractors are advised during training that secondary
containment is required on all portable restrooms. Declining to disclose
the number of new stores that will be built this coming year, Gallagher
did note that they had 306 construction projects last year and that it is
important to Wal-Mart that their contractors follow all the laws as they
pertain to the communities they are building in.
Christi Gallagher, contractors are advised during training that secondary
containment is required on all portable restrooms. Declining to disclose
the number of new stores that will be built this coming year, Gallagher
did note that they had 306 construction projects last year and that it is
important to Wal-Mart that their contractors follow all the laws as they
pertain to the communities they are building in.
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