Wednesday, February 3, 2010

SWPPP Employee Training - Stormwater Training Requirements FAQ

Stormwater regulations and most State and EPA NPDES stormwater discharge permits require some form of EMPLOYEE SWPPP TRAINING. Below are some common questions, or FAQ, Caltha receives regarding industrial stormwater pollution prevention training.



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.


Click here for more information on Caltha's Employee Stormwater and SWPPP Training Services



Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website


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Wednesday, November 26, 2008

SWPPP Training Videos and Stormwater On-line Training - Do These Resources Meet Requirements?

Many good training resources are available, including video training and “on-line” courses. Caltha often recommends these resources as an 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.

For example, here is an excerpt from a State permit that specifies training requirements:

Texas (TCEQ) General Permit:
Employee Training Program and Employee Education: A section within the SWP3 shall be
developed to establish a training program. Training shall be provided to all employees who are
responsible for implementing or maintaining activities identified in the SWP3. Employee training
shall include, at a minimum:
(1) proper material management and handling practices for specific chemicals, fluids, and other materials used or commonly encountered at the facility;
(2) spill prevention methods;
(3) the location of materials and equipment necessary for spill clean up;
(4) spill clean up techniques;
(5) proper spill reporting procedures; and
(6) familiarization with good housekeeping measures, BMPs, and goals of the SWP3.

...Education must be provided to those employees at the facility who are not directly responsible for implementing or maintaining activities identified in the SWP3, and who do not participate in the employee training program. At a minimum, these employees must be informed of the basic goals of the SWP3 and how to contact the facility’s storm water Pollution Prevention Team regarding storm water issues.

This this case, generic training materials would need to be supplemented with site-specific information on the facility's stormwater pollution prevention plan and site specific controls and procedures. Even the basic "awareness" training required for all employees needs to be site-specific.

Click here for more information on State-specific SWPPP - Stormwater Training Resources.


For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

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