Training on your environmental permits & approvals is often required to stay in compliance. Failure to train can cost you in fines, penalties, and violations, and endanger your employees because they won't understand what to do, how to act, or how to treat an emergency. Here we discuss why two key training areas often incorrectly get combined, and why you should never mistake these as the same thing.
One of my staff members just finished up an SPCC Training workshop recently. We had a large client in a room, and we went over, in detail, their SPCC Plan, what it is, why they need one, the works. At the end of the day, one of their guys thanked us for helping to kill two birds with one stone, and we really helped their staff a lot. Confused, my guy asked what he meant.
"Well we just got SPCC training. That covers stormwater training for our permit, right? We don't need to train again, do we?"
It's a good thing he said something because no, that's not right. Not even in the same ballpark. They're not the same, and shouldn't be treated as such. So yes you have to train again. SPCC Training & Stormwater Training - not the same.
Understanding Environmental Training
We get it. Your staff has better things to do that sit around and focus on training all the time. But, it's absolutely critical that you, your employees, your bosses, and whoever else, understand that stormwater training and SPCC training are very, very different.
So let's start with the basics. You have to perform training, and for most people, that means annual training. If you're really progressive, you might hold some sort of environmental compliance training once a quarter or once a month, and that's great! We find many of our clients struggle to get all their employees in the same spot once a year for training. Not only that, but just training once a year can overload and confuse employees due to the sheer volume of topics to cover. Sometimes people like to lump training together, and that's ok.
What's SPCC Training?
SPCC regulations mandate that every oil handling employee have annual training on the SPCC plan. This should include things like oil handling procedures, fueling procedures, tank and drum markings, spill containment practices, spill prevention equipment, emergency preparedness, emergency communications, and a whole lot more. There is a lot to cover. Consider you've got thousands of gallons of highly flammable liquids on a site, which may have heavy machinery and large equipment operating feet away from the containers. It's a hazard, and should be treated as such. This is training to keep your employees and facility safe in case of an emergency. This is important stuff! Training once a year is a requirement. You have to do it. Many of our clients find it's not enough, and conduct training on their SPCC Plan several times a year.
So how about stormwater training?
You likely have a stormwater permit for that same facility, which also very likely requires annual environmental training. Your stormwater regulations might not be as clear on who should be trained, but I’d say that anyone with any kind of site responsibility including management, environmental personnel or managers, operational people, and those who work at the site should be included. While it's not the same training for all employees – depending on their level of experience and responsibility with the permit – you should certainly cover issues such as stormwater BMPs, general housekeeping, site and stormwater inspections, and more. While some aspects of stormwater training certainly should include spill prevention and response procedures, it's clear it's not the same set of issues that you’d cover during training on your SPCC Plan.
So is all environmental training the same?
No, all environmental training is not the same. Passing off one form of training for the other won't work. It won't help your employees in case of an accident. It definitely won't help your operation should a problem arise. And if regulators have to get involved for any reason, you can bank on getting a violation for failing to meet your annual training obligations.
Do yourself a favor. Have clear, documented proof of any training. Keep records of any and all training. List your attendees, what you covered, how long it was, etc. You can do them together, but make sure you don't just do one. Do them both! You don't have to write up anything serious, but jot some notes down and keep yourself covered. Don't fake records. Don't lie. It'll come back to bite you should a problem arise.
Your best bet is to train multiple times a year. One of our clients includes brief training every month, and they lump it together with safety issues during a monthly company training session for all employees. Everyone knows what to do, what to look out for, and it works great for their organization. They keep great records, their employees actually learn a lot, and at the end of the day, they run an operation that hasn't had an issue with accidents, regulators, or any violations in many, many years. No violations and quick, easy visits from inspectors means more time for you to get back to business and make some money. It's a win-win for everyone.
If you're struggling to find time for environmental training, or looking to boost your employees understanding of the rules and regulations impacting your operation, click here to contact us or give us a call at 609-693-8301 to see how we can help with your training needs.