Semipublic Disposal System Inspection Program (HB110)

By implementing House Bill 110 (HB110) in 1984, the Ohio General Assembly created Ohio EPA's Semipublic Disposal System Inspection program (often referred to as the HB110 program). The program is a contractual partnership between Local Health Districts (LHDs) and Ohio EPA, whereby LHDs conduct, on behalf of the Agency, inspection and enforcement services for commercial sanitary waste treatment/disposal systems discharging between 0-25,000 gallons per day (semipublic).

Ohio EPA operates the program to better protect the public health and welfare, and to protect the environment. Due to the proximity, the multitude of facilities and the availability of resources, oversight of operations for sanitary waste disposal at semipublic facilities is best accomplished locally by qualified personnel.

To offset costs of local oversight, State law (Ohio Revised Code 3709.085) authorizes LHDs to charge fees for inspection services to be paid by semipublic facilities.

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Semipublic Disposal System and Small Flow On-Site Treatment System (SFOSTS)

By statute, a "semipublic disposal system" means:

“a disposal system that treats the sanitary sewage discharged from publicly or privately owned buildings or places of assemblage, entertainment, recreation, education, correction, hospitalization, housing, or employment, but does not include a disposal system that treats sewage in amounts of more than twenty-five thousand gallons per day; a disposal system for the treatment of sewage that is exempt from the requirements of section 6111.04 of the Revised Code pursuant to division (F)(7) of that section; or a disposal system for the treatment of industrial waste.”

In accordance with provisions established in ORC 3718 and in accordance with requirements of OAC 3701-29, GHDs may choose to implement the Small Flow Onsite Sewage Treatment System (SFOSTS) program. ORC 3718 defines a SFOSTS as follows:

"Small flow on-site sewage treatment system" means a system, other than a household sewage treatment system, that treats not more than one thousand gallons of sewage per day and that does not require a national pollutant discharge elimination system permit issued under section 6111.03 of the Revised Code or an injection well drilling or operating permit issued under section 6111.043 of the Revised Code.”

In implementing the SFOSTS program, the GHD takes on the responsibility previously under Ohio EPA authority of all permitting and enforcement aspects of SFOSTS in their given jurisdiction. Since there is potential conflict between the SFOSTS program and the semipublic disposal system program, clarification herein is provided to create a distinct separation of the programs. This distinction is as to when a facility crosses from one program area to the other. When the property in question pursues a permit to update or install a system meeting the SFOSTS requirements (e.g. similar to sewage, soil absorption and less than or equal to 1,000 gallon per day capacity) it is no longer a semipublic disposal system under Ohio EPA jurisdiction or subject to this MOU.

Inspection Program

In accordance with Ohio EPA's HB110 contracts, LHDs regularly inspect sanitary facilities at semipublic facilities for compliance with Ohio's water pollution control laws and regulations. Investigations of complaints regarding waste disposal by semipublic facilities are also accomplished locally. Ohio EPA also consults with LHDs on the approval of plans and issuance of permits-to-install (PTIs) for semipublic facilities. Installation inspections may be performed locally to ensure compliance with Ohio EPA's PTI conditions.

Enforcement Activities

In coordination with Ohio EPA, LHDs may notify entities of noncompliance with Ohio's water pollution control regulations. LHDs are also instrumental in identifying semipublic facilities installed without PTIs, of which Ohio EPA may not be aware. Where noncompliance notification and informal requests fail to correct violations, entities may be referred to Ohio EPA for enforcement or the County Prosecutor may bring an action under local nuisance ordinances. All discharges of pollutants which are unpermitted or in excess of permitted amounts are statutory nuisances under Ohio Revised Code 6111.04.

Training Program

Ohio EPA intends to provide periodic training for LHDs. Training programs will focus on sanitary waste disposal for semipublic facilities, technical assistance, inspection issues and enforcement case development.


The HB110 program is a unique opportunity for Ohio EPA and LHDs to assist one another in achieving the mutual goal of protecting public health and welfare. Through responsible regulation of semipublic facilities, the local community benefits from decreased health risks and the State as a whole benefits from improvements in water quality.

Ohio EPA welcomes the participation of all LHDs. Contact: Mark Stump, (614) 644-2028.

Per the MOU: Ohio EPA shall host a website dedicated to the Semipublic Disposal System Inspection Program for the purpose of providing resources and information relative to the program to support GHD inspection and compliance activities:

NPDES Permitted Facilities and Contact Information

The National Pollutant Discharge Elimination System (NPDES) requires a permit for all facilities discharging pollutants from a point source to a water of the state.

Professional Operators of Record

Each sewage treatment system discharging to waters of the state under terms of an NPDES permit, must be operated by a Professional Operator of Record licensed in accordance with Ohio EPA rules and regulations OAC 3745-7-04.  If the discharging system installed is identical to one that can be installed for Household Sewage Treatment System then that system can be operated by a service provider under conditions of OAC 3701-29. View the professional operators of record list online. 

Public Records

All reports, inspection letters, warning letters, enforcement actions, and notices of violation developed by Ohio EPA relative to these semipublic disposal systems that are considered public records will be made available on Ohio EPA’s publicly accessible website. You may search for Ohio EPA public records on the eDocs system

Training Programs

Ohio EPA's Compliance Assistance Unit works alongside local wastewater treatment staff to help identify performance-limiting factors and implement cheap, easy, and effective solutions. 

For district office contacts, please see our district home page or go directly to the county contact list. You may also contact Tony Nosko in the Central Office by email or phone at (614) 644-1978.


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