Industrial Pretreatment

Industrial Pretreatment

The Industrial Pretreatment Program regulates all industrial users served by MSD. There are approximately 1,500 regulated industries in St. Louis City and St. Louis County. About 200 of these are regulated and permitted in the pretreatment program. All industries must comply with MSD Ordinance No. 15048.

Industrial User Questionnaire

Federal regulations require MSD to identify the character and volume of pollutants contributed by industrial users. Industrial users can provide this information to MSD by answering a questionnaire in Article VIII, Section 1 of Ordinance No. 15048.

The questionnaire can be completed in one of two ways:

  1. On paper:  Print the blank document, then write the answers on the paper.
  2. Interactively:  Right-click on the fillable form below, select “Save link as…” and save the pdf file.  Then open the file in a pdf reader to answer the questions directly in the pdf.  The fields also will calculate values and results for you automatically throughout the questionnaire.

1) Industrial User Questionnaire

2) Industrial User Questionnaire (fillable form)

3) Questionnaire Instructions

Industrial users regulated under certain federal regulations may be eligible to request reduced or surrogate monitoring for particular pollutants, or the use of concentration limits in lieu of mass based limits.  If your facility has been informed of this eligibility, the necessary forms to be submitted may be printed here, for completion and submittal with the industrial user questionnaire:

Pollutants Not Present Waiver Request

Pharmaceutical Reduced or Surrogate Pollutants Request

Equivalent Concentration Limits Request

Solvent Management Plan form

Commercial-Industrial User Short-form Questionnaire

Certain commercial and industrial users may also be asked to complete a short-form questionnaire.  This short-form questionnaire can be downloaded and printed from here:

Compliance and Enforcement

MSD uses a Pretreatment Enforcement Response Plan to mitigate violation of program requirements and standards. Informal actions, such as telephone notification, compliance meetings or notices of violation, are used.

When more formal and progressive enforcement is necessary, MSD’s ordinance provides formal enforcement tools, such as administrative orders, emergency actions, legal actions, revocation of permit and cost recovery.

When violations appear to be of a criminal nature, we request support from a higher authority. An Environmental Crimes Task Force serves the United States Attorney in the Eastern District of Missouri, where MSD is located.

Federal regulations require MSD to publish, on an annual basis, all industrial users found to be in significant noncompliance during the previous year. MSD uses fiscal years (July 1 to June 30) as the basis for its publication list. The criteria used to determine if an industrial user is in significant noncompliance can be found in MSD Ordinance No. 15048, Article II.