CESSWI Scope of Practice
Version: September 14, 2010
The Certified Erosion Sediment and Storm Water Inspector (CESSWI) program and certification was developed by EnviroCert International, Inc. This certification is intended to ensure registrants meet the Federal requirements including the US Environmental Protection Agency's National Pollutant Discharge Elimination System definition of “Qualified Personnel¡” and also meet the requirements of State and Local regulations that require qualified personnel.
The CESSWI, Inc. program is designed to work independently of or in combination with the other EnviroCert International certifications such as the Certified Professional in Storm Water Quality (CPSWQ), the Certified Professional in Erosion and Sediment Control (CPESC), and the Certified MS4 Specialist (CMS4S) programs and to identify individuals with tested and documented skills who can perform erosion and sediment control and storm water inspections.
Purpose and Intent
The purpose of the CESSWI, Inc. program is to certify individuals who are technically and ethically qualified to provide inspections services for compliance with Federal (EPA NPDES and others), State and Local regulations. Permit holders will know that the CESSWI they are working with has met specific criteria and has been evaluated as a competent technical inspector. The CESSWI knowledge of Federal, State and Local requirements will allow CESSWIs to best inspect and advise permit holders of the necessary practices and proper techniques to apply planned erosion and sediment control and storm water BMPs. CESSWIs have the necessary knowledge to recognize if a permitted site is in compliance with Federal (NPDES), State and Local requirements.
The CESSWI, Inc. program addresses all aspects of providing complete inspections for erosion and sediment control and storm water compliance within the Federal (NPDES), State and Local regulations. Inspectors are qualified in construction, post-construction, multi-sector, industrial and commercial erosion and sediment control and storm water inspections. The CESSWI program recognizes the importance of documentation, communication and safety as well as an understanding of the rules and methods of erosion and sediment control and storm water control and management.
The CESSWI, Inc. program requires that a registrant certified as a CESSWI have a thorough understanding of the regulations governing erosion and sediment control and storm water management including but not limited to the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permitting program. A CESSWI registrant will also have a detailed understanding of the State and Local regulations for the area in which they practice. A CESSWI registrant must understand their role in evaluating sites for compliance with erosion and sediment control and storm water regulations for construction, post-construction, multi-sector and municipal separate storm sewer systems (MS4).
To maintain order and civility on a site, the inspector must be professional, impartial, courteous, consistent in every situation, honest and accurate with your response. In order to accomplish this, the CESSWI must investigate an entire site, provide verifiable written documentation and maintain the documentation as required law. The CESSWI recognizes the need for pre-construction and pre and post -inspection meetings and regular communication to be effective. Additionally a CESSWI must develop and have strategies for dealing with difficult people. The CESSWI program recognizes that an inspector is often placed in situations of having to deal with difficult people, difficult or problematic sites or deliver unpleasant findings to appropriate individuals. If this information is not delivered correctly a bad situation can quickly get heated.
The CESSWI program requires that a CESSWI be aware of the risks of injury associated with the profession and the steps to take to identify these risks and avoid injury. The CESSWI must understand the purpose of Personal Protection Equipment and those items that are required and those that are strongly recommended. In addition the CESSWI must understand the need to recognize toxic and hazardous substances that are often on sites and how to recognize proper storage and be able to evaluate Materials Safety Data Sheets and spill response requirements.
The CESSWI Program requires that the CESSWI have an understanding of the proper methods and procedures for documenting inspections. It is understood that all information collected as part of an inspection has the potential to be used in legal proceedings and enforcement cases and needs to be clear, concise and impartial. The documentation needs to completely describe existing site conditions in a non-biased manner and reflect what is required by approved plans. Included in the documentation is the management of site plans to document site conditions, tracking compliance and corrective actions and addressing possible complaints and enforcement actions.
- Inspector Duties
The CESSWI program recognizes that a CESSWI registrant plays multiple roles on a site including being the “Official” Representative on-site, a fact finder and record keeper, an enforcement case developer, and a technical instructor. As such a CESSWI must understand the measures necessary to prepare for, conduct and report on an inspection. The CESSWI must ensure the presence of critical documentation and exercise good professional judgment.
- Plan Management
The CESSWI program recognizes that the CESSWI must know the components of a Plan (i.e. Storm Water Pollution Prevention Plan (SWPPP) or Storm Water Management Plan (SWMP) or Erosion and Sediment Control Plan (ESCP)). While it is not expected that the CESSWI be able to develop the plan itself, they should be able to understand and maintain the records to ensure compliance with applicable laws and regulations. In addition, the CESSWI needs to understand the components of the plan and be able to notify the appropriate entities if portions of the plan are incomplete or not in compliance with regulations.
- Best Management Practices
Best Management Practices (BMPs) cover a wide range of measures that are used to reduce or control sediment, storm water and other pollutants within a specified area, these are divided into several areas including site planning and management, erosion control, runoff control, sediment control, post construction measures, and good housekeeping measures. A CESSWI needs to know and understand a variety of measures whose use and application will vary from site to site. The CESSWI will need to know the following information from the various BMPs -
- Description & Purpose
- Objectives & Targeted Pollutants
- Implementation Considerations
- Potentially Associated BMPs
¡ The US EPA's National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) defines “Qualified Personnel” as …
“a person knowledgeable in the principles and practice of erosion and sediment controls who possesses the skills to assess conditions at the construction site that could impact storm water quality and to assess the effectiveness of any sediment and erosion control measures selected to control the quality of storm water discharges from the construction activity.”
The USEPA's NPDES Multi Sector General Permit (MSGP) defines “Qualified Personnel” as …
“those who possess the knowledge and skills to assess conditions and activities that could impact storm water quality at your facility, and who can also evaluate the effectiveness of control measures.”
The US EPA Municipal Storm water Permit (MS4) 40 CFR Section 122.34 requires municipalities (both Phase I and Phase II) adopt ordinances and procedures to carry out inspections to identify Illicit Discharges, to perform Industrial and Commercial facility inspections, to perform Storm Water Management inspections for Municipal Operations, and to perform Long Term Post-Construction inspections.
Specific States and local governments may have other specific requirements.