Thursday, February 24, 2011
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.
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