No doubt, stormwater compliance is a document driven activity. Yes, you have a physical construction site just outside your job trailer that has hundreds of moving parts, of which your BMPs (best management practices) are just one part. And yes, getting those BMPs selected, installed, and maintained is the “real world” of stormwater management.
The Importance of Documentation
But along with those tangible elements of your stormwater management program comes the responsibility to document all your compliance activities. To protect your project and to protect the environment, you will have permits, Stormwater Management Plans (with their many parts), and you will also have inspection reports.
As a compliance company that performs hundreds of inspections a month, we occasionally encounter confusion about our client’s responsibilities when it comes to signing inspection reports. We routinely and happily help our clients with this, but if you are not yet a client, we still want to steer you in the right direction.
So first consider the inspector’s signature. When the inspector visits your site and observes all relevant stormwater management activities and measures, they will create an inspection report. In addition to an Action Item list, the report includes a space for the inspector and the client to sign the report. It is important to note that the inspector signs the report when it is created, not when all items are completed. Even more important is the understanding that the inspector is legally signing the report with the understanding that the report is “accurate and complete to the best of their knowledge”. This creates a burden and responsibility on the inspector to stand behind their report
What about the client signature? As noted in the language shown on the screen shot above, the client is signing when the action items on the report are ALL completed and nothing noted on the report is an outstanding issue on site. So if there are multiple action items on the report, each one can be “closed out” by adding a date and initial when that particular items is addressed and completed. But the Compliance Certification signature should only be added by the responsible party when every item on the action item list is complete, and then it will be dated to match the date of the last Action Item completed.