Tuesday, November 23, 2010

Storm Water Thoughts...Credentials

It's been a while since I last wrote on this site. I've been very busy making a living, writing SWPPPs, doing Site Inspections, speaking at conferences and providing NPDES Training to numerous companies. I just heard the other day that there are people in California passing themselves off as QSPs, Qualified SWPPP Practitioners, and QSDs, Qualified SWPPP Developers. I've written about this before, but apparently there is still some misunderstanding. Per the new California Construction General Permit (CGP) or NPDES Permit, individuals developing SWPPPs must by July 1st of 2010, be precertified (per Section VII of CGP Permit, or Table 9 of the Fact Sheet)see table below.


On the other hand a QSP must be certified by September 2nd 2011. So what does this all mean. In the case of the QSD, as mentioned, you must have successfully completed the pre-requirements (see table above) to develop a SWPPP after July 1st of 2010 and complete a QSP/QSD class (provided by a State Registered Trainer of Record, CASQA)and RWQCB Exam prior to September 2nd 2011 to continue on as a QSD after September 2 2011. The QSP on the other hand needs to complete the pre-requirements (see table above) and then take a QSP class(provided by a State Registered Trainer of Record, CASQA)and RWQCB exam prior to September 2 2011. Unless stipulated by contract requirement, the QSP is not neccessary until September 2, 2011. The QSP/QSD class takes 3 days (24hrs) and covers the Construction General Permit. The first 2 days meet the QSP requirements, the 3rd day meets the QSD requirements. If you are checking to see if your SWPPP preparer (QSD) meets the pre-requirements and you know they are not a California PE, check out the following website: http://www.cpesc.org/ , if you want to see if your Inspector / BMP Installer (QSP)meets the pre-requirements check out the following websites: http://www.cesswi.org/ci-default.asp , or http://cisecinc.org/
Although the QSP requirement doesn't go into force until September 2nd of 2011, I am seeing contracts daily that have built the requirement into the specifications already.

I have seen a great demand for training for people that need to get into the QSP pipeline so there organizations will be ready when all projects will require a QSP. To understand the QSP process, depending on your experience and training, you may require formal training prior to entering a CISEC or CESSWI program, remember you can sign up for the class anytime, but you cannot take the class exam without pre-approval by these organizations (CISEC or (CESSWI)InviroCert), I have recently heard pre-approval is taking 30 to 45 days. The CISEC or CESSWI review class and exam take 2 days, the primary focus is on Inspection, and is based on a National Model (EPA) with what I would call a municipal perspective. The QSP class, provided by a State registered Trainer of Record, see CASQA site for specifics: http://www.casqa.org/ , including names of companies and a calender of classes from various providers. The QSP Class takes 2 days, and the focus is on learning how to navigate through the California Construction General Permit. Through the CASQA site you can also sign into the State Water Board Training Academy to reserve a seat for testing. You must provide proof of QSP class attendence and ID when you go take your test (approx 3 hrs). If you have questions with regards to best strategy for your organization with regards to QSPs, how many do I need etc., feel free to contact me at (949) 351-1547.