We explain the concept of environmental training from a compliance perspective.
Environmental compliance isn't just a nice idea, it's mandatory. You are required to adhere to and follow any and all applicable environmental laws and regulations that impact your operation and facility. Just like following tax codes or obeying local traffic laws, environmental laws can't be ignored. The problem is, they can be tricky, complicated, and usually require a considerable amount of training.
I've been on a bit of a training kick lately. From attending a few seminars to conducting a couple of in-house training webinars, to facility specific on-site training, it seems like it's 'education month'!
One thing that I'm a big advocate of is simple environmental compliance training. I recommend it for all my clients, for anyone who's in charge of a company's environmental program, and really for anyone who interacts with environmental permits and approvals in any way.
The problem is, most people have no idea what I'm talking about and I normally hear
What is environmental compliance training?
Everyone knows they have permits, they have rules and practices they have to follow, but how do they keep track of it?
What is environmental compliance training at its core?
Remember when you first started driving? Can you imagine if you walked into the Department of Motor Vehicles on your birthday, they just printed out a license and off you went? No training from your parents, school, or some other person experienced in driving?
Crazy idea isn't it?
So what did they do? They made sure you had driver's training, in school or from someone else. That you had a certain level of knowledge about what you're supposed to be doing before they gave you the keys and you hit the road.
Getting an environmental permit may not carry the same risk as driving on a busy crowded highway at high speed, but I hope you get the analogy.
In the case of environmental permits, it usually means things like you didn't implement your BMPs, you're not keeping records, you didn't send in your forms on time, etc.
Compliance training at its core is training on the overall concept of your environmental program, including permits, approvals, and requirements, how they relate to your operation, and what you need to do to stay in compliance.
So what should environmental compliance training actually cover?
A good environmental training session should really cover the following:
Training should occur regularly.
Any good training occurs on a regular basis. Think about your personal life. Do you go to the gym? Or take any sort of classes, or have a hobby? You need to stay on top of whatever you're into. Take those same principles and apply them to your environmental program. We recommend training on various environmental topics either quarterly or monthly.
Environmental training should be for everyone!
Of course, different employees should receive different training, but everyone should know something. Everyone interacts with your company at your facility in one way or another, and indirectly they interact with your permits and approvals. For nearly every environmental permit, there's a role nearly everyone can help with. Let them know, via training.
Environmental training should be comprehensive.
Your training should cover every permit and approval that you have. Obviously if you're training every month, don't go over the same thing every time. Mix it up. Chances are your facility has a stormwater permit, air permit, SPCC Plan, does hazardous material reporting like CRTK Reporting or TRI Reporting, recycling procedures, etc. You need to cover everything!
If you're one step ahead of the curve and have an environmental management system, train on that as well!
All environmental training should be documented.
Do more than just pass around a sign-in sheet. How often do we see someone dozing off, or taking phone calls, or day dreaming?
How often do you test to see if someone actually listened and understood what they supposedly trained on? Put some teeth in your training program. Don't just make it something for employees to do to pass the time rather than their regular job.
For instance, our recording training includes software to track who's actually watching the webinar. Skip ahead, we know it. Fast forward, we know it. Occasionally we add in quizzes and if you're not paying attention to basic concepts, we go back to the previous section to start over again.
Environmental training shouldn't be dreaded.
Don't make your staff loathe the idea of environmental training. Do something to make it exciting. Do something! Do it during lunch and buy everyone pizza, delay the facility opening by a half hour and have a continental breakfast, give away a prize or offer an incentive for folks to participate and interact with the training. Employees should look forward to environmental training. It empowers them in their jobs, it raises their awareness of what you're doing, and they become active participants in your environmental efforts.
Training should be led by an expert.
If you're not 150% sure about what you're doing and discussing, don't teach others on the subject matter!
I recently had a client tell me they conducted a companywide training session on their stormwater permit. At first I was thrilled!
Then I realized this client has gotten several violations in the past 2 years, continues to fill out forms incorrectly, and still doesn't have a full grasp on their permit and its requirements. I checked over his 'syllabus' and it was riddled with errors and incorrect information.
He did a disservice to the entire company, and I let him know that it honestly was not a good idea for those reasons. His was response was 'some training is better than no training' which isn't true at all.
Training should only be done by someone with a firm grasp on the subject matter. You don't want to disseminate incorrect information or lead your staff astray. Many environmental regulations carry stiff penalties if they're not adhered to correctly. Don't give your staff wrong information which they, you, or your company could be responsible for.
If you want to hire and expert and then become the company expert, that's great, but don't pass yourself off as knowing this stuff when you don't. Don't bluff it, don't fake it, because the consequences of not following regulations can be severe.
I don't have enough material to cover for monthly environmental compliance training!
I hear this all the time and it's not true. Even if you just have an SPCC Plan and stormwater permit, you've got several topics to go over.
Take SPCC training for example. You could do a general SPCC overview and what it is. Fueling procedures. Spill response procedures. An emergency drill. How to perform an inspection or identify problems. How to handle and store 55-gallon drums.
If you covered one topic every other month, that's a year's worth of simple training courses.
I should get started with training ASAP, huh?
Yes. Take a look at your environmental permits, your NPDES permit, your air permit, your SPCC plan, your hazardous materials registrations, whatever. I guarantee most of them have annual training as a requirement, so for many regulations, you don't have a choice, it must be done.
But the more often you conduct training, the more benefit you and your staff will get out of it.
Ask yourself this, right now as you're reading this. Do you have an environmental training program? If the answer is yes, then you're ahead of most other companies. If the answer is no, you're probably on borrowed time, awaiting some sort of compliance problem, and likely going to need help sooner than later.
If you don't have an environmental training program, keep our number handy - you're probably going to need us. To learn more click here to contact us or call us at 609-693-8301 to discuss your training needs today.