Stormwater training is almost always required, but when and how often should you conduct SWPPP training?
We frequently get asked "why do we need training again, nothing's changed?" Well, all environmental training is sort of like going to the gym. You need to keep going, and keep practicing, because like anything else in this world, practice makes perfect.
Chances are you have a stormwater permit. You're just like hundreds of thousands of facilities all over the US. Maybe you have to do stormwater sampling. Maybe you don't. Maybe you have a complicated, complex permit. Maybe it's 10 pages long.
Regardless of what the details of your stormwater permit are, virtually every permit available in the United States requires some form of annual stormwater training.
A fairly common scenario we run into is this:
A facility has had a permit for years and recently ran into some type of trouble. Could be regulators cracked down on samples exceeding limits due to a poorly run program. Could be a 3rd party environmental group demanding to inspect and see training documents (which they legally can, and frequently do). Regardless, there's an issue, so we try to find the reason why.
Once you start following the breadcrumbs the answer becomes clear. Let's use a recent client as an example of what I mean.
They received a violation. We started digging into it. Their sample was bad. Really bad. Turns out the guy taking the sample had no idea what he was doing and used dirty equipment. Also turns out that a sweeper truck that normally cleans the facility had broken down, and no one was cleaning anything up. Additionally, no one was conducting monthly inspections of the facility, the outfall, or the samples being taken.
The employee responsible for the sample and maintaining aspects of the SWPPP flat out didn't know what they were doing. They weren't keeping up on what the best stormwater BMPs for their facility were, didn't know how to take a good stormwater sample, and didn't know how to conduct monthly inspections.
Our solution was simple. Let's do some training and get you up to speed. I almost fell off my chair when this guy asked....
Is stormwater training required?
Regardless of whether it's required or not, clearly your program isn't working at all, so what else would you recommend we do?
Certainly, that employee could be fired and a new, more competent employee could be brought in, but let's give the guy a chance and a proper education and see if we can turn things around.
Is stormwater training required?
The short answer is yes. And so is the long answer.
Training on the particulars of your stormwater program and SWPPP is almost always required. I have yet to come across an NPDES stormwater permit anywhere that didn't require training.
That's right, training isn't just a good idea, it's specifically required by your permit. If you aren't getting trained or conducting training, you're out of compliance. End of story.
There's no it depends, or maybe this that or the other thing. Yes, it's required.
What type of stormwater training is required?
Now we're getting into it a little more.
Let's take the example above back into consideration.
We ended up providing an environmental training workshop for the employee in question, a co-worker of his, and an additional facility representative.
Why?
To make sure there were several people on the same page. If employee A is sick / on vacation / not following the rules / gets fired, employee B or C can step in and help out, or run the program, or provide assistance, etc.
The old adage is "failing to plan is planning to fail", and that rings true here. There aren't usually requirements on what training entails, but we tend to go by the following rules and find they bring our clients the best results:
Training based on your stormwater permit and SWPPP.
Usually, canned training doesn't cut it. It's too generic, too wishy-washy, and relies too much on general principles.
Get training on your permit, your plan, and your facility. You will benefit the most from training tailored to you.
There are some cases where a particular set of procedures, requirements, etc. is pretty standard across the board. For instance, for those who need to perform a field pH analysis, generic pH training can be suitable. After all, you'll need to know how to calibrate and use your meter the same way, regardless of your permit.
Repeat often for best results.
Think about going to the gym, or playing basketball, or learning a hobby.
The more often you put time into it, the better the results. The same goes for training.
Most regulations state one training session is required per year.
We say no good. In fact, from our experience, facilities that conduct environmental training throughout the year have the best results (meaning the least amount of environmental issues).
For instance, a great client of ours used to conduct monthly morning safety training sessions to stay on top of OSHA requirements. They ran afoul of some environmental issues because they were only training once a year and didn't really think environmental matters were very important. We advised them to start incorporating environmental training in a similar monthly fashion, and after spending time developing 12 monthly training topics, and committing the time and energy to educate the necessary staff member, they have yet to have another issue with their environmental program. By dedicating time and resources to educating their employees frequently, they completely eliminated any issues.
Point is, train often, train frequently.
Training the trainer.
We frequently find the best way to conduct training is to have a resident expert at your company. Maybe it's you, maybe it's not. Regardless, many companies we work for hire us to train their environmental manager, who will then, in turn, conduct training for additional employees.
Usually, we'll jump-start an environmental training program by conducting at least one round of comprehensive training to a dedicated person or team. We'll also work to help facilities establish their own training program, such as implementing monthly environmental training like I mentioned above. That way we can ensure that all employees, at some point, get some level of annual stormwater training, appropriate to their job level and responsibilities.
For lack of a better term, we're teaching you how to fish so you can turn around and do the work yourself. We find it works great for companies, as long as the staff member responsible for training gets additional training as needed so they stay sharp and knowledgeable on the subject.
Other Considerations
Here are some other things to consider:
- In-Person vs Computer Based: Usually, in-person training is better than passing along computer-based software or training slides or something similar. Obviously, your needs and operation may change what's possible, but we always recommend in-person training. Think back to your schooling days. Things (at least for me) were always easier to learn when someone was there discussing and reinforcing the points being taught.
- Keep Training Records: Your permit is going to require that you keep documented training records. Keep track of who, when, and where training occurs. Keep information on what's discussed. Make sure you document training and keep the records of it either in your SWPPP or an appropriate folder.
- Different Training for Different Employees: Different folks should learn different things. The person who first greets visitors at your facility should know how to handle regulators showing up for inspections. The owner or manager of the facility should know about the program, but might not need every detail. The person taking the samples should be well aware of how to collect proper samples to ensure the best results. Point is, you should conduct training as appropriate for different staff members.
- Incorporate multiple types of training: Do you need SPCC training annually as well? If you have an SPCC Plan, then you certainly do! How about air permits? Maybe you have mock spill cleanup drills. If you're already conducting some sort of training, see if you can incorporate and combine training topics to make things easier on you and your staff.
- Keep it light, keep it accurate: I've seen training programs that have been incorrect. I've seen documented training records indicating one 6 hour-long training session on one topic. Newsflash: that doesn't work! You need to make sure your training is education but also absorbable. You want your employees to learn and remember what they're seeing. Don't overwhelm them. Don't overload them. And most importantly, make sure the information is correct!
I need stormwater training then, huh?
You bet.
Training, as I said, is required, almost universally across the board when it comes to stormwater permits.
Need help with stormwater training?
For a lot of folks out there, stormwater training is a pain to deal with. After all, you have a business to run! If you're overwhelmed, you're not alone. RMA has been actively involved in helping companies get and stay in compliance with stormwater permits across the United States since our founding in 1992. Long story short, we know the ins and outs of the environmental problems industrial and commercial facilities face and can help you get into compliance with stormwater permits (that includes training!) and other applicable environmental laws and regulations, ensuring your business stays out of trouble and in compliance.
Our staff members have been on-site at thousands of operations across the country, so when we say we've seen it all and done it all, we mean it. We've helped everyone, from globe-spanning, multi-national organizations to small "mom & pop" operations. No matter your size or location, we'd love to learn how we can help.
So, if you're in the need of stormwater training, or have any other type of issue at your facility and need the help of an environmental consulting firm with a proven track record, reach out. Even if we can't help, we’ll do our best to steer you in the right direction. Feel free to contact us at info@rmagreen.com, click here to contact us, or give us a call anytime at 888-RMA-0230 to learn how we can help your facility deal with stormwater permits and other environmental regulations.
Additional Stormwater Permit Information
Environmental Compliance: Simplified
Green Strategies: Elevating Beyond Compliance
Environmental Training: Empower and Educate
Phase I Environmental Site Assessments
Data Centers
Cannabis
Marine
Concrete
Investors / M&A
Warehouses
