BUSINESS INSPECTION PROGRAM REPORT
EDUCATION AND OUTREACH
BUSINESS INSPECTION PROGRAM REPORT
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Acknowledgments
This survey report was prepared by Business Inspection Group (BIG) members Susan
McCleary, Laurie Larson-Pugh, and Heidi Zarghami.
BIG would like to acknowledge the collaborative efforts of staff that contributed to the survey
and the jurisdictions that generously contributed information about their programs:
Clark County
Cynthia Hickey
Alison Schweitzer
King County
Laura Heron
City of Seattle/SPU
Pierce County
City of Kent
Rod Swanson
Snohomish County
City of Lakewood
City of Tacoma
Dani Driscoll
Ryan Langdon
Tally Young
Kurt Freemont
Kristina Lowthian
Ken Waldo
Jeremy Graham
Erik Lust
Diana Halar
Larry Schaffner
With guidance and review by:
Meridith Greer
Diane Hennebert
Rachel Konrady
Chris Thorn
Purpose and Disclaimer:
This report compiles information about current business inspection programs conducted by
jurisdictions within the Puget Sound region. The purpose of this report is to support local
jurisdictions with the development and implementation of business inspection programs that
enhance the protection of water quality from sources of pollution.
Not all aspects of a Source Control Business Inspection Program are included in this report nor
does it obligate any jurisdictions to follow recommendations provided. For more detailed
information about Source Control requirements of the Washington Municipal Stormwater
Permit, please visit: https://tinyurl.com/vbxgfv6
For information or questions about this report:
Laurie Larson – Washington Stormwater Center
Phone: 253-445-4593 Email: [email protected]
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Table of Contents
List of Abbreviations & Acronyms
Introduction and Acknowledgements
Survey Method
Report Layout
Section 1 – Education and Outreach
Section 2 – Code and Code Enforcement
Section 3 – Data Collection and Management
Section 4 – Inventory Development and Updates
Section 5 – Inspection Protocol
Section 6 – Program Management
Appendixes
Appendix A.
Survey Template
Appendix B.
Source Control Program for Existing Development & Appendix 8 (S5.C.8)
Appendix C.
Public Education and Outreach Resources
Appendix D.
Code and Code Enforcement Resources
Appendix E.
Inventory Development Resources
Appendix F.
Inspection Protocol Resources
Appendix G.
Program Management
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List of Abbreviations & Acronyms
4 Appendix 8- An appendix to the NPDES Permit’s Source Control Program for Existing Development
4 BIG – Business Inspection Group is a collaborative workgroup consisting of jurisdictional inspectors,
NPDES coordinators, program managers, outreach and water program specialists.
4 BMP(s) – Best Management Practice(s)
4 EAM – Enterprise Asset Management
4 Ecology – Department of Ecology (referring to Washington State Department)
4 ECOSS – Environmental Coalition of South Seattle
4 FOG – Fats, Oils & Grease
4 FTE – Full Time Employee
4 GIS – Geographic Information System
4 IDDE – Illicit Discharge Detection & Elimination
4 ISWGP – Industrial Stormwater General Permit
4 LSC – Local Source Control (program) refers to hazardous waste pollution prevention
4 MS4 – Municipal Separate Storm Sewer System
4 NAICs/SICs Codes –Numbers or codes attached to specific business types for the purpose of
identification or classification
4 NOV – Notice of Violation
4 NPDES – National Pollutant Discharge and Elimination System
4 SAW Database – Secure Access Washington Database
4 SOP – Documentation of standard operating procedures
4 Source Control – The practice of reducing or eliminating the cause or source of pollution
4 Stormwater Asset – A structural stormwater management component
4 Super – Superintendent
4 SWPPP – Stormwater Pollution Prevention Plan
4 TMDL – Total Daily Maximum Load, refers to the maximum amount of pollutant loading to waters of
the state
4 QC – Quality Control
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Introduction
With the issuance of the 2019-2024 Western Washington Phase II Municipal Stormwater Permit,
jurisdictions across the Puget Sound region are required to develop and implement a Source Control
Program for Existing Development. This is a preventative, inspection-based program focused on
addressing pollution from existing land use activities that have the potential to release pollutants to a
Municipal Separate Storm and Sewer System (MS4). To fulfill permit obligation (S5.C.8 see Appendix B)
permittees are required to meet the following objectives within the term of the permit:
o Establish an inventory of public and private commercial and industrial sites with the
potential to generate pollutants to the MS4 by 8/1/2022.
o Adopt and make effective an ordinance(s) requiring the application of operational or
structural source control BMPs for pollution generating sources associated with existing land
uses by 8/1/2022.
o Implement a progressive enforcement policy requiring sites to comply with stormwater
requirements within a reasonable time period by 1/1/2023.
Permittees shall train staff who are responsible for implementing the source control
program to conduct these activities.
o Implement inspection program for sites identified in inventory by 1/1/2023
All identified sites with a business address shall be provided educational information
about pollution generating activities and source control requirements applicable to
these activities by the end of the permit term.
With the permit requirement in mind, the Business Inspection Group (BIG) conducted a survey to gain
knowledge of existing business inspection programs across the region. This report provides detailed
information to Western Washington Permittees by providing examples and best practices to address
various elements of a business inspection program.
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Survey Method
This report compiles information gathered by BIG via a comprehensive survey developed and reviewed
by regional experts (BIG members and others). The Source Control Business Inspection Program Survey
can be found in Appendix A.
BIG invited eight jurisdictions currently implementing business inspection programs (both Phase I and
Phase II) to participate in a survey interview. All eight jurisdictions were happy to accept, and all but one
survey was conducted in person. Interviews were conducted between August and December of 2019.
Survey implementation teams were formed on a voluntary basis to conduct survey interviews. Teams
consisted of two jurisdictional staff, and in most cases from a geographically close jurisdiction, to
decrease travel times. Survey interviews were transcribed, not recorded, and names and affiliations were
deleted from the transcripts to ensure anonymity. All transcripts were reviewed by the participating
jurisdiction for accuracy before being compiled.
Respondents were also asked to provide examples of enforcement strategies, checklists, outreach
materials, codes and training materials. These items can be found in the Appendix section of this report.
Report Layout
This report is broken down into six sections outlined in the Source Control Business Inspection Program
Survey. Each section references a requirement of the NPDES Permit’s Source Control Program for Existing
Development (S5.C.8).
Each section is organized by a survey question, and the corresponding responses from the eight
jurisdictions organized into a table format. Each response table is followed by a summary of key themes
from the respondents.
Each topic section ends with an overall summary, recommendations, and a link to the appendix and
resource documents, when applicable.
The report concludes with the Appendices, which contain resource and reference documents.
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Survey Responses
EDUCATION AND OUTREACH (S5.C.8.b.iii)
Question 1.1 What type of outreach was done prior to implementing business
inspections?
Respondent
Comments
Respondent 1
Prior outreach managed by the Solid Waste program as toxics reduction and
recycling promotion (some site visits and outreach materials).
Some prior site visits and some outreach materials to Small Quantity Generators
of Dangerous Waste.
Respondent 2
Notification letters mailed prior to inspection program.
Respondent 3
No specific outreach was done prior to implementing the NPDES-required source
control inspection program.
Prior robust education and outreach program was dismantled in early 2000’s
resulting in minimal staff for business outreach.
Respondent 4
No outreach prior to starting program.
Approached inspection as an opportunity to educate on how to do it “clean”.
The jurisdiction partnered with the health department to conduct tandem
inspections with the jurisdiction as lead. The health department had their own
process for conducting inspections.
Messaging was kept consistent throughout jurisdiction programs.
Respondent 5
Prior business outreach was conducted before the permit requirement.
Respondent 6
In 2006-2007 an education and outreach mailer was sent out to businesses to
notify them of future permit inspections.
Public advertising was conducted through events and media.
First inspection for new businesses is a technical assistance Audit type inspection
that has less strict enforcement triggers.
Respondent 7
Business outreach began in 2008 in response to S5.C.7 of the Phase 1 Permit.
Outreach materials were mailed to businesses in pilot study.
Door-to-door inspections were conducted after pilot study.
Respondent 8
Outreach prior to program is unknown.
Site visits were conducted to refine business inventory and for initial education
outreach.
Summary
Before implementing business inspection programs, many of the jurisdictions mailed notification letters
to businesses or conducted public advertising alerting them of the program. General stormwater
pollution prevention, education, and outreach for business was not conducted in most of the surveyed
jurisdictions before beginning their business inspection program.
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Question 1.2 Do you conduct ongoing outreach? For example, for new businesses do
they get a heads-up regarding the purpose of the inspection?
Respondent
Comments
Respondent 1
The permit requires that all business sites in the inventory be provided with
outreach during the permit term.
A mailer is sent to the entire inventory.
Respondent 2
Yes, ongoing outreach is conducted.
New businesses receive information about the program’s purpose both in letter
and in-person.
Inspector often obtains correct business information during site visit.
Respondent 3
New businesses do not get a heads up, because we do not know when businesses
start up.
There is no business licensing program that could provide this information.
Respondent 4
Ongoing outreach done at the time of inspection and at any follow up visits.
The jurisdictions focus is to develop a relationship as a resource for the business
with every inspection, the jurisdictions message is “We are here to help.”
The jurisdiction provides a spill plan at the time of inspection.
Respondent 5
Ongoing outreach is done through site visits, outreach materials, and online
information.
Door hangers are left when no one is present.
Mailings go to the business owner and the property owner.
Would like to have more improved online resources for outreach and education.
Respondent 6
No ongoing outreach to new businesses is conducted.
Initial site visit is a technical assistance visit.
Inspector often obtains correct business information during initial site visits.
Annual business license review process generates audits for new businesses.
Respondent 7
No notification of the program for new businesses when they open.
Inventory is parcel based; therefore, do not keep an ongoing list of businesses
that open and close.
Small business inventory was improved through canvasing techniques.
Any parcel in the inventory that did not receive an inspection during the five-
year permit cycle receives informative notification about the business inspection
program.
Respondent 8
Ongoing outreach for new businesses conducted
Expressed interest in adopting outreach for new businesses.
Considers outreach materials ineffective unless connected to business
compliance.
Inspectors are supplied with educational materials to hand out during site visits.
Building permit application may trigger outreach if obvious violations are
present.
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Summary
Ongoing outreach for new businesses seems dependent on whether an extensive business license
inventory is available. Ongoing inspections are usually focused on high-priority businesses, and ongoing
outreach materials about the permit are generally distributed throughout the regions.
Question 1.3 Please provide examples of outreach and distribution timeline if available.
See resources listed in Appendix C
Question 1.4 Are you providing incentives or recognition to businesses that are regularly
in compliance?
Respondent
Comments
Respondent 1
Compliant businesses are encouraged to pursue recognition in a local “Green
Business Program”.
Respondent 2
No recognition for compliance currently offered.
Expresses an effort in planning a future recognition program.
Respondent 3
EnviroStars program has undergone a major reboot and have not had any
referrals yet.
Incentives are provided in the form of free spill kits if the business is inspected as
part of the LSC contract with Ecology
Frequently provide information on the jurisdiction’s Hazardous Waste Voucher
program and strongly encourage utilization.
Respondent 4
No incentives are provided.
Jurisdiction recognizes compliant businesses at quarterly council meetings and
distributes calendars with compliant business coupons.
Respondent 5
No recognition program is currently offered.
Recognition program was discontinued as it was time-intensive and seemingly
little benefit, and due to lack of new applications.
Respondent 6
No recognition program is currently offered.
Outside programs such as the LHWMP voucher program, ECOSS spill kits, and
EnviroStars are available to businesses.
Respondent 7
No recognition program currently available.
Expressed interest in creating an incentive program.
Respondent 8
No recognition program is currently offered.
Potential to participate in new EnviroStars program.
Summary
Most respondents do not have a recognition program for compliant businesses, but there is a stated
interest for, and some initial planning of future recognition programs. The EnviroStars program was a
common outside source for business compliance recognition. This program is currently undergoing
changes.
Question 1.5 Have you developed outreach materials and/or letters of non-compliance
for ESL businesses? See resources listed in Appendix C
BUSINESS INSPECTION PROGRAM…