PHAB Compliance, Wastewater, and Sanitation: What Property Owners Need to Know - Texas Commercial Wash

PHAB Compliance, Wastewater, and Sanitation: What Property Owners Need to Know

Many times we discuss why it is important to clean your property.  Image and safety are always the top of the discussion.

Here we are going to discuss PHAB (Public Health Accreditation Board) and how this ties in with what we do.  It is also important to know that The Houston Department of Health and Human Services is recognized by PHAB and their enforcement is also aligned with PHAB’s policies and procedures.

There are two major areas they focus on regarding the pressure washing industry.  Wastewater management and environmental infection protocol.  

Wastewater management is what we will cover first.  The main concern with wastewater is that the oils and contaminants are entering the storm drain which runs directly into our bayous and in some areas goes directly into the Galveston Bay.  This obviously doesn’t mean runoff doesn’t occur.  When someone has an oil leak in a parking lot, and it rains that oil will reach the storm drain.  And with that being said is why a routine maintenance cleaning schedule is necessary for a busy business.

Did you know that if someone has an oil leak in your parking lot, it rains and then that oil goes into the storm drain the facility is liable?  This law isn’t just regarding the city of Houston, this is a national EPA guideline referring to the waste water recovery act and is a national standard.

Something to think about, do you have a broken down car in your parking lot?  Have you ever wondered why companies tow broken down vehicles from their parking lot?  If a car is broken down and sits for an extended period of time, sometimes there can be an oil leak or even a defective battery that is leaking battery acid (as indicated when you see a large orange stain that looks like rust).  When it rains it will run off this waste into the sewer system and at this point the owner of this property is liable.  This is why it is important to remove abandoned vehicles.  If your property is vacant and not being used, this is NOT a defense to prosecution on this incident.  Even an empty lot where a company has gone out of a business can be liable for run off which now is more than a tax liability, it is now a legal liability.  So make sure you are removing abandoned vehicles from your parking lots to prevent this from happening.

Water can be removed several ways and there are different methods to do it, but the ultimate goal is to make sure it doesn’t enter the sewer system or on to another property.  Imagine if oil or battery acid was like trash, would you feel comfortable using a leaf blower to send wrappers and cups into the storm drain, onto the public roadway or onto your neighboring businesses parking lot?  Hopefully not.  The same goes for fluids.  It is recognized as “wastewater” which is essentially “solid waste in fluid form”.

Now a maintenance program is just how it sounds, it is maintenance.  You likely won’t see a large cosmetic difference when you get your parking lot cleaned regularly.  Because that isn’t always the intended purpose.  A lot of parking lots are cleaned regularly to prevent environmental issues in the future and the cosmetic benefit is just an added benefit to the service.  Many companies will only get their sidewalks cleaned for the curb appeal aspect of their business and completely neglect their parking lot.  Many companies wait to power wash their parking lot until it needs to be restriped.  Why do companies frequently get their parking lot restriped?  Because many times an enforcement agency like the fire marshall’s office is requiring them to do so.  

Although you will rarely have a fire marshall visit your business about waste water, there have been instances where they have paid an unpleasant visit to either us, or one of our customers in reference to waste run off, or waste run off prevention.  In our case we had a tank that carried bleach sitting outside our shop that did not have a containment berm in the event of a failed gasket.  They required us immediately to obtain a berm to prevent the risk of bleach run off and contaminating the city storm drain.  The Kemah Fire Marshall’s Office gave us a warning and advised if we were not compliant they would be shutting down our business until this was resolved.  We had this resolved in less than a day to prevent our business from being closed. 

We had a competitor in the City of Friendswood get caught by the Friendswood Fire Marshall’s Office cleaning a large diesel spill in a commercial parking lot and was caught pushing the waste water into the storm drain with a substantial amount of diesel.  They were fined and were told to leave the job site or they would be arrested.  This is not a situation anyone wants to be in and there are ways to prevent this from happening.  Make sure the company you hire is operating within the compliance standards of your city, all cities have regulations on waste water.

Now this next segment is a less frequently discussed nuisance (which is a word PHAB uses) is environmental infection control.

This is an especially important topic with hotels, restaurants, hospitals and entertainment.  We have a pretty extensive blog covering this already made here https://txcowash.com/blogs/news/restaurant-concrete-cleaning-why-restaurants-get-dirtier-faster-and-what-to-do-about-it

But we wanted to go a little further into detail PHAB heavily aligns with the CDC “Guidelines for Environmental Infection Control in Health-Care Facilities” which covers OSHA 29 CFR §1910.1030: Bloodborne Pathogens Standard, relevant for cleaning contaminated surfaces.

At many emergency hospitals this is a common contaminant and will sometimes have blood appear on the ground surface outside of the facility while bringing in a patient who has been badly injured.  Contrary to popular belief, the blood isn’t always contained on the stretcher and can easily access public easement.  It is mandatory to have a regular pressure washing schedule for areas that see this kind of foot traffic.  

Another thing that is not considered is that many entertainment areas will periodically have customers who may experience nausea and the area is simply just “mopped”.  It is important to note that the bacteria spread from this is microscopic and enters the porosity of the ground and can cause others to get sick.  Using pressure and chemicals used for sanitation are important to remove this bacteria at a microscopic level so that the area is actually clean and doesn’t just look or smell clean.

There are many sidewalks and parking lots where people spit (not just tobacco) and frequently need to be cleaned to prevent the spread of bacteria.  

Did you know it is illegal to spit on the sidewalks in New York City?  Under New York City Health Code Article 181, spitting on sidewalks, in public buildings, or on public transportation is strictly prohibited. Originally enacted in 1896 as an anti-expectoration ordinance, this rule is designed to prevent the spread of diseases like tuberculosis, prohibiting spitting on any area used in common by the public.

Well guess what?  It is not just illegal there.  It is also illegal in some places in Texas.  One of them being in the Houston metro area.

Texas City: City ordinance § 94.002 explicitly makes it unlawful to spit on any sidewalk, in a public building, or in public transport vehicles.

El Paso: Code of Ordinances 9.84.030 makes it illegal to spit in commonly used public locations.

These laws were originally put in place because it was considered rude or gross but over time these laws stayed in effect because it was found that spit can spread tuberculosis and the laws have stayed in place because now it has become a safety concern.

Although there is not a specific law stating that you must power wash your sidewalk after it has been spit on, it is implied that you will maintain your property so that the property remains sanitary for the public to visit.

Did you know that you also have a responsibility to remove standing water on your parking lot if it is not draining properly?  Texas Health and Safety Code actually covers this.  Texas law prohibits leaving standing water that acts as a mosquito breeding ground. Texas Health and Safety Code § 341.011 classifies a place that acts as a breeding place for flies or mosquitoes in populated areas as a "public health nuisance," requiring property owners to abate such conditions.

To take this a step further we are going back to our popular topic, dumpster pads.  It is important to keep the top lids closed to prevent rain water from allowing mosquitoes to breed inside of the dumpster.  And it is important to keep the dumpster pad clean to prevent flies.  Flies and mosquitoes are considered a public health nuisance according to this statute.  And there is a good reason for this.  It isn’t just the right thing to do.  If you are a hospital or a restaurant that wants to promote better health, isn’t it counter productive to have a facility that has bad health practices?  Having a lot of mosquitoes can also damage your brand if you are a hotel or restaurant that has outside seating.  Proper cleaning and water management can help make the outdoor experience of your facility become a better one for your customers.

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