Draft Changes to the Georgia NPDES Construction Stormwater Permit

On December 15, 2017, the Georgia Department of Natural Resources – Environmental Protection Division (EPD) issued their draft NPDES Construction General Permit. If approved, the new permit will go into effect August 1, 2018.

Below is a summary of relevant changes:

  • As a result of the EPD’s implementation of the NPDES electronic reporting rule, ALL
    Notices of Intent (NOI), modifications to existing NOI’s, and Notices of Termination
    (NOT’s) MUST be submitted through the EPD’s electronic submittal portal:
  • The EPD is in the process of developing an electronic method of submitting water
    sampling reports via the electronic submittal portal. Notifications will be sent once this method is completed.
  • Plans required to be submitted directly to the EPD for review must now be submitted electronically via the electronic submittal portal or as a PDF file on a CD-ROM or other
    storage device.
  • The “self-reporting” of permit violations to the EPD has been clarified as follows:
    • Whenever a BMP has failed or is deficient and has resulted in sediment
      deposition into waters of the state, that constitutes a violation and a summary of
      that violation must be submitted to the EPD.
    • If the BMP that resulted in the sediment deposition does not require a new or
      replacement BMP or significant repair, the BMP must be repaired by close of the
      next business day from the time of discovery.
    • If the BMP that resulted in the sediment deposition requires a new or modified
      BMP or significant repair, the BMP must be operational by no later than 7
      business days from time of discovery.
  • Rainfall must be measured and recorded within the disturbed areas of the site that have
    not met final stabilization once every 24 hours except any non-working weekends and
  • Coverage under the infrastructure construction permit (GAR100002) is not required for
    construction projects that consist solely of the installation of cable barriers and guardrail
    within existing rights-of-way, and the installation of buried utility lines.

The public commenting period is 30 days from the date of the public notice. A public meeting regarding the draft permit is scheduled for January 31, 2018. The content of the comments and results of the public meeting may alter these proposed changes. Contact HB NEXT for any other questions pertaining to Storm Water or Environmental Services.

2017 OSHA Regulation Changes Review

2017 saw a year of changes and modifications to OSHA regulations as the safety industry tries to support the labor workforce in keeping their work environment a safe place to be. HB NEXT is committed to supporting construction firms in understanding and complying with OSHA regulations. HB NEXT Senior Instructor/Consultant Raymond Scott reviews some of the 2017 OSHA changes.

  • The year saw the end of the silica controversy and the adoption of the new standard.  We have seen the industry struggle to even come close to achieving the new standard.  Fortunately, OSHA gave us the T-1 table. If followed, this relieves us of meeting the standard. The first round of lawsuits were concluded Dec 22, 2017, with the courts upholding OSHA. For the time being, we are stuck with the standard. The biggest issue may lie in the B-reader test being used. This is the same procedure used in “black lung” and asbestos testing.
  • Subpart CC had the operator certification pushed to November 10, 2018.  Note, this does not relieve the employer from the responsibility of ensuring operator training.
  • Residential construction continues to be OSHA’s focus with over 6000 fall protection citations issued to home builders.
  • Electronic reporting of form 300a got off to a slow start due to technical issues on OSHA’s end with the filing date extended to December 15, 2017.  Next year, we will have until July 16, 2018. Moving on from 2019, we will have to meet the original March 2 deadline.
  • OSHA has finally recognized the importance of safety training for first and second line supervisors in leadership. It is sorely needed, and they are encouraging it in their Outreach Training 500, 502 Classes.
  • We have seen OSHA starting to push the residential industry to address attics and crawl spaces as confined space.
  • With the new administration’s pro-business approach, we expect to see a slowdown in new regulation over the next few years with a possible review of existing rules.

Staying abreast of OSHA regulation changes is critical to providing a safe work environment and minimizes the impact on project budgets before fines are imposed. HB NEXT is here to serve in a support role for construction firms’ safety and compliance business units. Contact HB NEXT today for any questions regarding your OSHA compliance situation.