We explain whether or not you need to do annual SPCC training.
Last week I did a 5 year review for a client's SPCC plans. Everything looked great. The site hasn't changed, no spills, great monthly inspections. There were some new personnel on site which needed to be added to the plan, but other than that it was a breeze!
Expect... they weren't doing annual SPCC training at all! The new head honcho decided that training once, 5 years ago, was all his employees needed. I asked him what he did for new employees. They did nothing. He said "I don't have time to train my staff. Besides, this stuff is all common sense."
Not only is that the wrong attitude to take when it comes to keeping your staff safe, and your facility free from mishaps due to neglect, it could get you in trouble. No, this stuff is not always common sense, and yes, you need to be conducting annual SPCC training at your operation.
It's a vital to keep your staff knowledgeable of what happens in an emergency, how to react, who the call, what to do, and keeps them safe. Yes it may be common sense to some, but it's not a guarantee. It's also absolutely required to happen at least once annually, and not conducting training will get you some hefty violations from the USEPA.
Just having an SPCC Plan is not enough. You need to conduct annual SPCC training.
Yes, You NEED to do Annual SPCC Training
You may, just like this new guy, be wondering "why":
- Annual SPCC training is required. You have to do it. It's not up to you. The government says so, and they enforce it if you're not doing training. They also enforce people who lie about training, whether that's faking records or whatever they consider lying. Violations are expensive, and you can't afford to neglect this simple requirement.
- SPCC training keeps problems from happening. Training teaches your staff who can fill, fuel, inspect, use, move, touch, or do anything with any oil drums or tanks. Do you let anyone just waltz into your operation and start messing with whatever they want? No, and neither should you let just anyone handle potentially thousands of gallons of a highly flammable, dangerous substance.
- SPCC training teaches communication to your staff. By training, your staff will understand that they should be noticing things out of the ordinary, including spills, leaks, drips, etc. Your staff should know they should be reporting things like this to someone. Additionally, your SPCC Plan outlines just who that someone is, and by training on it, your staff members know who to go to, and how to get a hold of them in an emergency.
- When #!@% hits the fan, SPCC training teaches you how to react. Employees need to know what to do during an emergency, such as a spill, rupture, or tank on fire. Who do they call? What should be done? How do they keep themselves, the facility, and if possible, nature safe? Where can they find all this information quickly? Without training, your staff might run around like chickens with their heads cut off. We we conduct training, we do emergency scenario training, to test what facility personnel know.
Here's the best way of looking at it: without any SPCC training, having an SPCC plan is just having another book on your shelf in the office. Meaning, it's kind of useless. It's not an effective tool to help minimize emergencies.
So if you're not conducting annual training, start now. Do it next week.
If you are conducting annual training, is it working? Is it enough? Is your training adequate to keep your employees educated? Test your staff and find out.
Bottom line is get into compliance, keep your staff educated and safe, and steer clear of any potential disasters, and start with at least annual SPCC training.