QSP / QSD Training in California

We are now down to less than 30 days until you will be required to be a QSP to inspect your projects. Even with the partisan dysfunctional behavior of Washington and Sacramento everything appears to be on track.

July's QSP/QSD class went well with 28 people attending, a good group of people with a lot of field experience and great interaction. The next class (QSP Only) is scheduled for August 12th and 13th and as of today, is more than half filled. As a result, I have had to schedule a 2nd class (QSP/QSD) this month for August 25th, 26th and 27th. I will also be teaching a CISEC class August 30th and 31st in Gardena. Despite all the bickering of our representatives, business continues to be looking up, and appears to be moving along in fits and starts. Currently we have around 8 SWPPPs on the books for the month, and the month is just starting, as well as a new series of QSP inspection contracts. Several new QSP's will start working for CAL-Storm next month. As to the various clients out there, well it's a mixed bag of private, public, state and local, as well as a smattering of federal. If there is one comment to make, it is that we have now reached a state where the consultants are consulting the consultants, with all the inherent issues of self justification that this process requires, specifically SWPPP reviewers with various levels of competency making comments in order to justify their positions with the agencies. Personally I like the challenge, and view it as peer review that allows me to see other perspectives, even when they appear to be inconsistent, and at times pedantic. If there is one thing that professional life has shown me, that is that we all operate with our own personal bias, and that although it is at times challenging to understand an others perspective, there is always a new opportunity to learn and improve the final deliverable.

On another note, I am still coming across GC's that do not have a clue, can you spell BMP? It amazes me to see organizations that have either because of ignorance, or arrogance, chosen to be oblivious to the changes around us. Knowledge and understanding of the regulations, documentation, BMPs, implementation and inspection requirements are the keys to controlling the cost of compliance. It's not a difficult concept, if you understand how the pieces fit together, you can develop the processes to minimize the impact to your bottom line.

To get people to understand the motivation, and neccessity behind these standards I use the analogy of air pollution in Southern California. Imagine what the air quality would look like had we not taken steps to reformulate the gasoline, combined with new emission controls 40 years ago. Given the amount of growth in this area the air quality of Mexico City would look like paradise compared to LA. But as a direct result we seldom have smog alerts warning people to not venture out or schools closed because of air quality issues. The other example I use is OSHA and safety in general. Many of us long for the good old days, when we weren't constantly scrutinized by these agencies, forgetting as an example, the time when old Charlie the factory worker, lost his arm in the machine and had the gaul to survive, he got sent home with no pension, no disability or other recourse, except a half days pay and a hearty "have a good life", next...(and so it went on with no improvements to safe working conditions.

According to the EPA, 40% of the waters of the US are unswimmable, unfishable, or undrinkable. You may have heard about how the Soviets managed it with centralized planning and how they in there "socialist" ways destroyed the pristine wilderness that was Siberia...we in our free market democracy should be able to do better, I do expect more...(Gulf Oil Spill, Yellowstone Pipeline, Exon Valdez)

What's wrong with this picture?

Storm Water Thoughts June 1st 2011

3 months and counting. September 2nd is fast approaching to meet the State QSP Certification requirement. To recap earlier posts, every active construction site that is subject to the CGP must have a QSP assigned to perform weekly inspections, as well pre-rain, post rain and others. Other requirements for QSPs include, REAPs, Rain Event Action Plans,and testing and sampling of storm water for turbidity and pH on Risk Level 2 and 3 sites. The training requirements for a QSP are: field experience, formal training, application and acceptance into either the CISEC, Certified Inspector in Sediment & Erosion Control, or CESSWI, Certified Erosion, Sediment & Storm Water Inspector Programs (2 days / $350 +/-). You must be preapproved to sit for the exam on the second day for either program. (Check out CISEC or CESSWI website for application requirements) The second requirement is to complete the QSP class from a registered Trainer of Record (2 days / $400 +/-)(Check out CASQA website for ToR Schedule). Once you have your QSP class scheduled, then schedule your QSP class through the State Training Academy link on the CASQA website. There is no charge for testing. The test is open book, i.e. the Construction General Permit, and it is absolutely essential to read the permit as well as taking the class. You must present your offical CA ID and Letter of Completion from the ToR to sit for this exam. Each organization or company is making decisions on the number of QSPs needed to meet the requirements. Issues to consider are: number of projects, geographic spread of projects, risk level of projects etc. Each of these factors will go into the decision as to how many QSPs are needed, e.g. a couple projects in close proximity to each other could be legitimately handled by a single QSP.

QSP / QSD 6 Months and Counting

It appears that there is still a great deal of confusion over the certification requirements of California's New Construction General Permit. In a nutshell, you must possess the pre-requisite certifications of a QSD, Qualified SWPPP Developer, to develop a SWPPP (after July 1st, 2010). These pre-requisite certifications consist of: CA-PE, CA-Architect, CPESC or CPSWQ. Anyone preparing a SWPPP without these qualifications is basically committing fraud with their clients. By September 1st 2011, individuals preparing a SWPPP will also need to have successfully completed a QSD class (24hrs typically) and passed the California State QSD Exam.



On the other hand anyone with the assigned responsibility and minimal training can perform the tasks of a QSP, Qualified SWPPP Practitioner until September 1st 2011, unless contractually specified otherwise. These tasks typically consist of performing the required weekly inspections, both written and visual, (all Risk Levels), as well as REAP, Rain Event Action Plans, and Turbidity and pH testing for Risk Level 2 and 3 sites. The QSP certification process consists of 4 basic steps; the first is general storm water, BMP, SWPPP training and experience, the 2nd step is the pre-qualification certifications of CISEC, (Certified Inspector, Sediment & Erosion Control-16hrs) or CESSWI (Certified Erosion Sediment & Storm Water Inspector-16hrs, (you must be pre-approved by these organizations to sit for the exam), the 3rd step is to take the QSP class (typically 16hrs) from a state certified Trainer of Record, and the final step is take the state exam at a state approved site, typically a RWQCB office or University.



It does not matter if you take the QSP class first or the CISEC/CESSWI programs first. The focus is different, yet complimentary for each step. The CISEC/CESSWI programs focus on understanding the responsibilities of a storm water inspector and both of these programs have a national (not just California) perspective. On the other hand the QSP class focuses specifically on the New California Construction General Permit, and your ability to navigate through it quickly and efficiently. The QSP exam is multiple choice and a copy of the permit is provided with all of the attachments, i.e. an open book test, but it's a big book. You must provide a letter from your Trainer of Record and CA-ID to sit for the exam. The exam is free, but closely monitored. The exams are currently booked solid until the summer as of this post.

As you can see California is trying to get people to realize that Storm Water is not a token issue assigned to the project intern. This effort is designed to get California compliant with national standards, apparently we have been lacking, and non-compliance potentially impacts our ability to get federal funding for new projects (jobs).

Compliance may seem dificult at first, but understanding and a little knowledge will ensure cost effective compliance...think OSHA or Smog Devices on Cars in California, and the improvements to our overall quality of life.