The
article below will hopefully provide some insights into
the profitablility of complying with new
environmental regulations affecting us all in the cleaning
industry.
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“How
to PROFIT from Strict Environmental
Laws & Drive Your Competitors Crazy”
By
Jerry McMillen
Increasingly
complex legislation for discharging wash-water into storm
drains means pressure washer operators and cleaning contractors
are now facing new challenges in performing what used
to be routine washing tasks.
The
problem: Storm drains discharge directly into lakes, rivers,
or the sea without any treatment whatsoever and thus pose
an environmental threat should polluted water (wash water)
enter the system. Strict Federal, State and Local ordinances
are being enacted which forbid anything but “precipitation
water” (rain and snow) from entering storm sewers
and also provide heavy penalties to those found violating
these rules.
Pressure
washer operators and, for that matter, anyone generating
wash/waste water, are becoming the object of intense municipal
scrutiny as these new regulations are enforced with more
regularity.
Some
Typical Municipal Regulations
Regulatory
laws identify “Storm Water Conveyance Systems”
as roads, streets, gutters or any other means of carrying
storm-water into lakes, rivers, or the sea. With very
few exceptions, it has become unlawful to discharge any
type of non-storm water into the “Storm Water Conveyance
System”.
Depending
on the locality, some of the exceptions are: individuals
washing their cars; excess lawn watering which flows into
streets and, those water flows resulting from fire-fighting.
Pressure-washing operations are definitely not among the
exceptions. Moreover, we are aware of pressure washer
operators being cited and fined merely for leaving small
residual traces of water on the ground with none of it
flowing away anywhere!
While
the above incident is an example of enthusiastic over-interpretation
of the regulations, the implications for the industry
are clear. Waste-water must be controlled and operators
must be trained in the basics in order to avoid fines
and bad publicity.
With
the concerns of residents and tourists alike at stake,
cities and towns are understandably nervous at the prospect
of polluted water from storm drains adversely affecting
the aesthetics of their river and beach areas.
As
an example of municipal interest in the pressure-washing
industry, the city of San Diego, California has issued
a set of laminated instruction cards giving a synopsis
of the regulations. These list and explain regulator defined
“Best Management Practices” which may help
in carrying out the intention of the law. The cards are
free to local owners and operators of commercial pressure-washing
equipment.
^Top
"Best
Management Practices"
The
San Diego “Best Management Practices” for
prevention of storm water pollution give a summary view
of what will be required nationwide in the industry in
the very near future. These recommended practices can
be summarized as follows:
Planning
for waste-water capture – Before starting
washing operations, plan how waste-water will be trapped
and collected to avoid entering storm drains and discharge
into streets. Plan what will be done with the collected
water. Arrange water barriers and covers so as to minimize
the possibility of an accidental discharge into storm
drains.
Cleaning
and washing activities - Use dry methods to pre-clean
and remove soil residues to approved containers if deemed
hazardous. Minimize amount of water used during washing.
If hazardous wastes are created during washing operations,
avoid mixing with non-hazardous wash water, to reduce
disposal costs.
Wash
water collection and disposal - Recovered wash
water may be recycled or otherwise disposed of in the
proper manner. The captured waste-water (if no hazardous
pollutants are present) may usually be discharged onto
landscaped areas with the owner’s permission and,
as long as there is no runoff to storm drains. However,
some beach communities located in regions of steep cliffs
forbid this disposal method. Also, some desert localities
prohibit ground discharge as it might harm native plants.
Otherwise,
the property-owners sewer connection (sink, toilet, etc.)
may be used if the flow rate does not exceed (typically)
20 gpm. Other fairly common restrictions include a maximum
discharge (without a permit) of 2,500 gallons per day
from exterior mobile power washing, and 25 gallons per
day (after suitable treatment) from engine washing.
Some
communities require (and charge for) a discharge permit
regardless of flow quantity. Many local codes are available
over the internet or by contacting your local city hall
directly.
^Top
Enforcement
Beware,
most regulations being enforced now come with teeth. Violations
of the no-discharge rules can be classed as misdemeanors
and (in San Diego) are subject to fines of up to $10,000
per day per violation, up to a maximum of $100,000 for
any related series of violations.
Other
localities may have lesser penalties but fines approaching
this magnitude are scary enough to oblige operators to
outfit themselves with the proper equipment and train
their personnel in water recovery as well as washing techniques.
Methods
for Complying with Wash-Water Control Laws
While
the rules, regulations, and enforcement codes are available
and definite, a real dilemma for the average operator
is how to comply. Commercially available techniques make
up a fairly short list:
Sump pumps
Wet/dry vacuums with internal sump pump (pump out systems)
Vacuum pumps
Vacuum berms
Portable dams, booms, and berms
Portable plastic wash mats and pits
Drain covers.
Tarps and hand equipment
Sump
pumps - For wash-water control use, these are
small units, typically completely submersible, which have
the pump inlet at or near the base, so as to remove standing
water. Typical submersible sump pumps have fractional
horsepower motors operating on power cords and will pump
30-40 gallons per minute at low head.
If
a low spot or an area created by portable dams or booms
can be arranged, water can then be pumped into a separate
holding tank or septic system (toilet, sink etc.). This
type of system is inexpensive though generally not effective
and, is adequate only if septic systems are close by.
Wet/dry vacuum with internal sump pump
– Vacuums of this type are especially useful for
sweeping up standing water from floors, walks etc, and
are typically much more rugged than the “shop-vacs”
sold to homeowners.
In
addition to having more powerful motors for applying suction
(up to 2 hp, typically), the vacuum tank includes a sump
pump to remove and discharge accumulated water to the
sanitary sewer (or other approved discharge area). The
maximum suction lift obtainable with these vacuums however,
is quite low for constant working conditions and pump
out capabilities are limited, at best.
Vacuum
pumps - Positive-displacement Roots-blower type
vacuum pumps are a giant step up in power and capacity
and, are advantageous in that they have the additional
power to screen and filter the recovered water as it is
picked up, thus reducing the need for additional equipment.
The higher power also permits multiples of 50 ft hose
lengths to the water recovery site.
Engine-driven
versions are also independent of possibly limited power
supplies required by electrically powered systems. Typical
units feature a 5 to 7.5 hp engine driving the blower
and are rated at a minimum of 12” mercury suction
at 200 cfm air-water flow. Larger capacity units are also
available. Units complete with vacuum berm, screen and
filter tank with automatic pump-out, hoses, etc, rated
at waste-water recoveries up to 40 gpm, are most appropriate
for professional cleaning contractors.
Vacuum
berms - These are flexible dams of around 4-6
inches height, which can be arranged to intercept ground
water resulting from washing operations. Hooked to a vacuum
system, they employ rows of holes at the ground surface
to suck up the water which has been corralled by the berm.
The
best designs trap and collect every bit of the water flowing
against the berm; a dry surface on the lee side of the
berm is common. Available in various lengths, these devices
are inexpensive, very effective and the most practical
method for the professional cleaner.
Portable
dams - These are 5-6 inch diameter soft plastic
tubes of various lengths (typically 4-5 ft.) which are
then filled with a heavy substance, either sand, a mixture
of sand and styrofoam pellets, or water, and arranged
to block, corral, or deflect running waste water into
collection areas.
The
weight and flexibility of these plastic tubes form a tight
seal against the ground surface, thus controlling runoff.
These tools are inexpensive, indispensable and two or
more should be on every contractor’s work truck.
Portable
plastic wash mats and pits - These are used principally
to control waste-water when washing vehicles, although
many other applications come to mind. They consist of
heavy plastic watertight sheeting arranged with foam or
inflatable berms all around, thus forming a catchments
area.
Typically,
vehicles are driven onto the wash mat with double berms
at each end to reduce the likelihood of water loss upon
entering or leaving the pit. After
vehicles are washed, the waste water on the pit is removed
with a sump pump or vacuum.
For
the general pressure-washing contractor, versions are
available to catch water from interior or exterior wall
washing, for example. Prices vary according to size and
function.
Drain
covers - These are plastic sheeting arrangements
designed to cover storm-drain openings as a precaution
against failure of other waste-water collection devices.
Several
versions are available. For
horizontal openings, a small version of the “wash-mat”
can be filled with water; the weight thus seals off the
area surrounding the storm-sewer grate. A version containing
magnetic material can be used where steel grating is present.
However,
it should be stressed that water approaching a storm drain
is already in the “Storm Water Conveyance System”
so drain covers are a precautionary measure or last resort.
Tarps
and hand equipment - Traditional, but not to
be forgotten equipment includes mops, buckets, and grease
absorbers for use before washing.
^Top
Complete
Water Recycling
Several
companies offer complete recycling systems which reuse
water originating from power washing. Basically
these systems consist of a portable storage tank of 50
gallons or so, which feeds the high-pressure washer.
Waste
water is then diverted by suitable dams or booms to the
entrance of a vacuum berm. The waste water is then conveyed
by vacuum pumps to a tank or series of tanks where it
is then screened and filtered. The resulting fluid is
then pumped out of the final tank and, through more filters,
by a sump pump in the tank to the storage tank for reuse.
The scheme is certainly environmentally correct, and may
be essential in locations where water must be hauled to
the site. A complete recycling is thus achieved.
Two
considerations involved here are perhaps minor: due to
evaporation, not all the water used in washing can be
recovered, and allowance for this loss, which may amount
to 20% or so, may increase the volume of storage tank
required. Another factor seems to be that the recycled
water gradually looses quality in spite of filtering,
due to bacterial contamination.
Training,
Certification, and Documentation
Since,
in most states, the property owner is also the legal owner
of the waste water produced at his property, actions to
prevent citation for violation of discharge rules by the
cleaning contractor or power washing operator should yield
significant competitive advantages.
These
actions would include not only the ownership and use of
proper equipment, but also training employees in how best
to use the equipment to meet environmental legal requirements.
This training should be passed on to all front-line personnel
in a structured way, complete with hand-outs and documentation.
Commitment
to proper procedures and, awareness of local environmental
ordinances should also impress your local regulatory authorities.
In fact, many municipalities have issued “Letters
of Approval of Environmental Power Wash Procedures”.
Also, a “Letter of Acceptance of Environmental Waste
Water” for operators discharging only to the sanitary
sewer system is another competitive possibility.
Undeniably,
approval such as this provides a significant competitive
advantage for the contractor who has planned ahead and
invested in his future. Certifying
that employees / operators have this training may be just
the competitive edge you need to win that next big contract!
Incidentally,
a comprehensive training course covering the topics of
this article will soon be available from the authors –
call for information.
^Top
The
Opportunities
While
the rules, regulations, and equipment necessary to meet
new environmental standards may seem burdensome, there’s
no sense trying to “Beat City Hall!” Operators
who gear up and prepare for these changes will not only
avoid painful fines and stressful regulatory harassment,
they’ll also be the ones who enjoy the most profitable
business opportunities in their respective markets.
As
mentioned earlier, we operate in Southern California where
environmental regulations have become a serious consideration
for all cleaning contractors and pressure washer operators.
In
just the past twelve months, we’ve seen how these
new policies have quickly changed the competitive landscape
in our market. For those business owners who have accepted
the changing laws and adapted, business opportunities
appear to be growing and, more importantly, improving
in quality.
Allow
me to explain.
In
San Diego, there are a large number of pressure washer
operators. Many are contract cleaners, some are auto detailers,
some are painters and other trades people who use pressure
washing equipment in their daily work.
We
serve most of these businesses through chemical or equipment
sales or, by providing service and repair work for their
machinery. Regardless of why they come to us, we have
noticed a trend. Those contractors who are adapting to
new environmental regulations are doing more business
than those who aren’t.
The
reasons are simple. Those business owners who have adapted
to the new laws are providing better service and better
value to their customers. Also, they are taking the time
to explain why it will benefit them to choose contractors
who are compliant with environmental regulations over
those who aren’t.
Quality
Service Pays
When
property managers and owners are given greater assurances
they will not be involved in legal disputes triggered
by untrained or poorly equipped power washing operations,
they are generally more willing to hire those companies
capable of providing these protections over those that
are not.
Moreover,
we’ve noticed that the higher quality customers
don’t have a problem paying more for services that
are more professionally delivered, environmentally sensitive
and, legally compliant.
In
sum, it is our observation that those contractors who
adapt to this new era of environmental sensitivity can
expect to have greater opportunities available to them
than their competitors, enjoy greater respect from their
peers and customers and, not the least of which, get paid
better money per manpower hour.
Undeniably,
professional cleaning is a respectable trade. Rather than
lament these new laws, we feel they will improve the industry
as a whole. Less committed operators will be winnowed
out and the industry will be improved and on the cutting
edge of professionalism and quality service.
^Top
Jerry
McMillen is the owner of Cleaning Systems Specialists,
a manufacturer of power washers and waste-water recycling
equipment in Santee, California. Dr. J.W. Hoyt, a consultant
to CSS, assisted in preparing the article.
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