Here we discuss what stormwater training is and what your staff members might be trained upon.
A lot of our clients turn to us when it's time to get environmental training. Whether it's a new employee, site conditions change, or it's developing a system of training throughout the year to ensure a total understanding of rules and regulations, we help companies stay in compliance with their various permit training requirements.
A common problem that we see, and what brings a lot of folks who are out of compliance into our office, is many people don't do their required environmental training. Or, their training is done so poorly and inconsistently that it ends up spreading misinformation, often resulting in regulators issuing fines, penalties, and violations in one way or another.
What is stormwater training?
Let's start by saying that nearly every stormwater permit we've ever seen (and we've seen a lot) has the requirement for some type of training. And, at a minimum, nearly every permit, probably including yours, requires that training to occur at least annually. It isn't just a good idea, it's required by law.
That means once per year, every year, no matter what, all employees involved with the program go through comprehensive training. We usually advise as many people are included as possible, so a wide variety of facility personnel understand the regulations, requirements, and rules regarding your permit.
Got it? Ok, so here's what training actually is.
Conduct regular, annual stormwater training.
We're clear on this, right? You have to do stormwater training at least once a year. Check your stormwater permit for any specific requirements you might have, but it's usually at least once per year. Doing it more is fine, and we encourage it, but it has to happen at least once!
Check your stormwater permit for specific training requirements.
Always, always, always check your permit first! For instance, we've seen permits that said that training had to be done at a specific location by a specific agency leading to a specific certification. Kind of unusual, but those are the rules. Most permits usually won't go into this level of detail. We find most just mandate annual training covering the basics of permit compliance. Additionally, make sure you're aware of any other caveats you may need to be trained on. For example, most stormwater permits specifically state that pH needs to be analyzed within 15 minutes of the discharge sample collection. For most, this means you'll need to analyze pH on-site. Do you know how to analyze for pH? Do you have a pH meter and know how it works? Do you have buffer solutions and know what to do with them? If not, you probably need to include some form of pH training, at least for the person who will be analyzing the samples. For a full breakdown of exactly what you’ll need to do to analyze the pH of your samples on-site, be sure to check out our online training course: The Best Way to Perform pH Analyses of Your Facility’s Discharge Samples.
Stormwater training has to be comprehensive.
It should cover all appropriate and applicable aspects of your program and should be focused on what's really important. I've seen training that others do that spends a lot of time talking about the legal background of the Clean Water Act for example, which draws glassy-eyed stares and yawns from attendees who really don't need to know the legal junk behind why the rules are in place. It should focus on your primary permit requirements, site inspections, stormwater sampling procedures, reporting procedures, what inspection and sample results mean and what to do about them, where the SWPPP is located, what BMPs are implemented at the facility, and how they should be maintained, specific BMP reinforcement, etc. It shouldn't be generic. It should talk directly to your staff at your operation.
Stormwater training is going to take some time to get through.
If you have one session per year, and blow through it in 15 minutes, that's not cutting it. Expect that a real training session is going to take at least an hour or more. Training time is going to depend on the size and intricacies of your facility and permit, your staff's level of understanding, the number of employees included, and other variables. Regardless, make sure you allot some time for this.
Include as many people as possible in your training session.
Trust me, don't just include your environmental person. They already kind of get this stuff. Include shop managers, maintenance guys, site workers, field workers, machinery operators, etc. The more buy-in and understanding you have, the better the chance you'll have a more successful environmental program. If you're only doing training for a few employees, it's probably not going to work out too great.
Not everyone has to be trained at the same time.
Perhaps the level of training complexity provided to management is different from that provided to the technical staff responsible for inspections and sampling, which is still different from the training provided to the rank-and-file employees. How are you going to get them all done at once? We usually suggest different training at different times - to each group at least once per year, is the best way to go.
Stormwater training should be by someone who knows their stuff.
You would think this is a given, but hire an expert! Get someone with a real strong grasp on your permit, its requirements, and how they impact your facility. Again, generic training usually is ineffective from what we've seen, but a lot of folks have claimed success by using canned training. Do your homework and make sure the trainer is well educated and also passionate and lively. How many terrible training sessions have you sat through before? This stuff isn't too exciting, so getting someone who can entertain and train is a home run. If you have someone on staff, that's great, but consider getting an outsider every now and then to reinforce the topics.
Document your stormwater training.
If you don't have records, the regulators will think it never happened. We've seen violations for poor record-keeping, or not keeping any records, so do yourself a favor and keep some sort of proof of the training. Jot it down on paper, get 'training certificates' from the person doing the training, keep a copy of the training outline and the attendees, including the date and length of training, etc. Be specific with what you record. What did the training consist of, and how long did it go on for? Who did the training? Where was training held?
Consider your training options.
We always recommend on-site training, based on your stormwater permit, your SWPPP, your site conditions, and your staff's level of understanding. However, you can go about it in other ways. There are training videos, webinars, computer-based training with testing, training at conferences and seminars, etc. Figure out what works best for you and your staff.
Stormwater training is better than a good idea... it's required.
I hope you're not still wondering what stormwater training is! Break it down to its core values, and it's easy to understand and remember: Annual, documented comprehensive training covering your permit requirements and responsibilities done for as many employees as possible, and taught by a qualified person.
Think to yourself, are you doing stormwater training? Do you have a program running, right now, that says we do annual training for all applicable employees? Have you done it yet this year? Was the training performed by someone who knew what they were doing?
If the answer to any of those is no, you could have a problem on your hands. Regardless of which direction you go, you need training.
Need additional information on stormwater permits?
Check out some of our other articles for helpful stormwater permit information:
Does your facility need help with stormwater training?
For a lot of folks out there, the details of stormwater training are 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 (including training!) 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 up to speed with stormwater training and into compliance with stormwater permits 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 having any type of issue with your stormwater program 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 firstname.lastname@example.org, 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.