Many industrial and manufacturing facilities in the U.S. are required to provide training to their employees (and possibly also contractors) as a condition of their State or EPA stormwater discharge permit. This posting addresses some of the more common questions Caltha is asked regarding stormwater training.
Spilled Corrosive Liquid From Aboveground Tank
1. What Kind of Training is Required?
The answer will depend on the State your facility is located in – different States will have different training requirements. However, Caltha generally sees three categories for training:
a) SWPPP Awareness Training. This is “high-level” training which may be given to all employees, and covers basics of stormwater program and facility controls that would apply to any employee.
b) Stormwater Training. This training would be addressing employees whose day-to-day work activities relate to the specific controls and procedures the facility has established in its SWPPP, such as dock workers who might be involved with spills.
c) Stormwater Permit Compliance Training. Employees who have been assigned specific compliance tasks, such as conducting inspections, collecting stormwater samples, need to be trained to conduct their tasks.
2. Can I Use Generic Training Materials?
Many good training resources are available, including video training and “on-line” courses. Caltha often recommends these resources as a element of a facility’s training program. Whether or not these types of “off-the-shelf” training resources meet the training requirements will depend on the specific requirements for your State. In many cases, training needs to include information on the facility SWPPP, and therefore the“off-the shelf” resources need to be augmented with facility-specific training.
3. Does Every Employee Need to be Trained?
Possibly. However, as described in #1 above, not all employees need to have the same level of training. In addition, other factors, such as ISO 14001 registration, may require that you consider training contractors working at your facility.
4. How Often Does Training Need to be Presented?
Many States require annual refresher training; however, some training might only be presented once, such as Permit Compliance Training.
5. Does Stormwater Training Need to be Documented?
Yes, because training is a requirement of an NPDES discharge permit, records need to be maintained to demonstrate that all affected employees received the appropriate training.
6. Do Our Trainers Need Special Training?
This is not addressed in most States; however, effective trainers need to understand their subject matter. Caltha offers a number of “train-the-trainer” options.
Caltha LLP | Your EH&S Training and Compliance Training Partner