Routine stormwater inspections are designed to identify issues before they turn into larger compliance problems, but what happens when something doesn’t meet requirements? When deficiencies are noted during an inspection, they’re documented as corrective action items—specific issues that must be addressed to keep a project in compliance. Understanding what these corrective action items mean, how they’re classified, and what steps are required to resolve them helps contractors and owners respond efficiently, minimize risk, and keep projects moving forward.
What Are Corrective Actions?
Corrective action items are required responses when stormwater control measures (CMs or BMPs) are found to be inadequate, damaged, improperly installed, or ineffective during an inspection. These actions are intended to restore compliance and ensure stormwater controls continue to function as designed. Corrective actions may range from simple maintenance, such as picking up trash or patching a small hole in a silt fence, to more involved repairs or redesign of permanent stormwater features.
Maintenance vs. Inadequate Action Items
In Colorado stormwater inspections, deficiencies are often categorized as either maintenance issues or inadequate (or ineffective) control measures. While both require corrective action, the distinction affects urgency, documentation, and potential enforcement risk.
Maintenance Action Items
A maintenance action item refers to a stormwater control measure (BMP or CM) that was properly designed and installed, but may show signs of normal wear, sediment accumulation, or minor damage but does not affect its overall functioning.
These issues typically arise over time and are expected as part of routine operation and maintenance.
Common maintenance action items include:
- Slight sediment buildup in silt fence, inlet protection, or detention basins
- Trash or debris throughout the site
- Minor erosion that does not indicate system failure
- Street sweeping from minor trackout
In Colorado, maintenance items are usually expected to be corrected promptly and documented in the inspection report. When addressed in a timely manner, they generally carry lower enforcement risk, especially when records show consistent inspections and follow-through.
Inadequate (or Ineffective) Action Items
An inadequate action item indicates that a stormwater control measure is not sufficient, improperly installed, missing, or failing to meet permit requirements—even if maintenance has been performed.
These findings suggest a more serious compliance concern because the control measure cannot effectively manage stormwater as designed.
Common inadequate action items include:
- Missing required BMPs or permanent control measures
- BMPs installed incorrectly or not per approved plans
- Controls that are undersized for site conditions
- Repeated failures of the same BMP despite maintenance
- Permanent stormwater features that do not meet design criteria or no longer function
Inadequate action items often require repair, replacement, or redesign, not just maintenance. In Colorado, these issues typically come with shorter correction timelines (usually within 24 hours) and may require additional documentation, engineering review, or follow-up inspections.
How Colorado Inspectors View the Difference
Colorado inspectors (CDPHE and local MS4s) generally view:
- Maintenance items as expected and manageable with routine care
- Inadequate items as higher-risk findings that may indicate noncompliance with permit conditions
Repeated maintenance issues that are not resolved can eventually be reclassified as inadequate, especially if they lead to discharges or water quality impacts.
Staying Ahead of Compliance
Corrective actions are a normal part of stormwater compliance. The key is knowing what’s required, acting quickly, and maintaining clear documentation. Working with experienced stormwater professionals can help ensure issues are identified early, corrective actions are properly implemented, and compliance is maintained throughout the life of the project.