Here we discuss why you need annual training, who benefits from it, and what its goal is.
A lot of our clients initially came to us when they needed help with their stormwater permits. Whether they received a violation, needed to get covered under a permit or needed help with their stormwater plan, at the end of the day, they all had some new rules to follow which includes things like sampling, inspections, or stormwater training.
One of those rules was annual training, to which a lot of folks would turn around and say "Why do I need stormwater training?"
It's a great question, and I completely understand the inevitable push back. Normally folks within an organization will think I'm responsible for helping them with their stormwater program, so I'm the only one who needs training, which isn't necessarily true.
Who needs stormwater training?
Let's get this clear from the get-go. Training is a requirement of virtually every stormwater permit I've ever seen. Regardless of your industry, facility, or state, the chance is pretty good you need at least annual training at your facility for staff members who interact with your stormwater plan.
Since no successful – and compliant – stormwater management program can succeed without the knowledge and cooperation of all employees, it is critical that all employees have at least some form of training on stormwater issues on an annual basis.
So what I'm saying is if you want your program to be successful, you need to have several members of your staff included in training. We normally recommend multiple staff members receive training at your facility, from facility personnel, to managers, to upper management.
Does every company employee need to be trained on accounting procedures, or equipment maintenance procedures, or some other very specific aspect of the way a business runs? Of course the answer is no; certain jobs require certain skills. Let the accountant handle the business accounting, and let the maintenance guy handle the equipment procedures.
The problem is good sound stormwater management doesn’t really work that way. There is no way one person can handle this, and make it work.
That might come as a shock, or maybe you’re signing off this post right now thinking “this guy’s crazy, our environmental guy handles that”. You’re thinking certainly YOU don’t need training. In all likelihood, you’re wrong, and you could pay for that mistake.
For instance, what happens if they're out of work when an inspector shows up? Or if someone has to take a stormwater sample, but the environmental guy is the only one who's trained?
Additionally, and I really hate to say this, but what we normally see is one environmental person in charge of stormwater at a facility, and we see it rarely works. Did they receive initial training, and do they know what they are doing? That sounds like a no-brainer, but I can’t tell you the number of times we’ve seen the environmental manager having little to no understanding of what their responsibilities are under the law.
So we really have three issues here:
- Key Personnel Need Training - The person or people directly involved in stormwater management need comprehensive, annual training. They need a good, solid understanding of what's supposed to be done, including when, how, and why they're doing it. There's no skirting the issue here, they need training, including refresher training on a regular basis. The success of the environmental program at your facility is depending on their knowledge and understanding.
- Backup Personnel - Anyone who's there to support the key personnel need to receive training. Like I mentioned above, imagine if there's a problem and some of the key personnel are not around in case of an inspection, or sampling is needed. You have to have backup people to not only fill in for key personnel, but to keep other facility members informed.
- Everyone Else - This is the rest of your staff, which doesn't necessarily need training, but should be familiar with some basic rules regarding the permit, and some basic stormwater BMPs. I'll explain more below.
So who really needs stormwater training?
Why does the key personnel need training? Isn’t it enough just to have a permit, and let them get back to “real work”? No, unless you enjoy violations, penalties, and fines. Because that’s what you’ll get when your key personnel don’t understand things like how and when to do inspections, or how and when to take stormwater samples the best possible way, or how to document their findings, or how to report their findings to the regulatory agency, etc., etc. While this isn’t rocket science, it also isn’t second nature.
But why does everyone else need training also? Because everyone has a role; some large, some small. Everyone has to participate in your stormwater management program to an extent.
For example, a key component of stormwater management is housekeeping as a best management practice (BMP). Every employee can play a part by understanding the importance of keeping the facility clean and free of trash.
Another example is fueling procedures for those facilities with fuel pumps. Understanding that small spills can add up to a lot of stormwater pollution – through training – will result in more attention, fewer spills, and less stormwater contamination. While not everyone needs to know the complexities of stormwater sampling or other regulatory requirements, everyone needs some form of training.
Important aspects of stormwater training.
- It has to be done right the first time. If key personnel “get it” and then they are capable of further training your staff, that’s great! But they need to be properly trained in the first place.
- It needs to be regular. Most NPDES permits require annual training. We recommend doing it twice a year in short meetings to get the message across. We've found anything less is too infrequent for the message to sink in.
- It needs to be appropriate to the level of employee. Think back to the accountant; he or she needs to be trained on the latest tax code information, but everyone else can just be trained on payroll procedures. While some need to know everything about stormwater compliance, others don’t, but they should at least be able to have a basic grasp of why it’s important at the plant and what they can do to help.
Virtually every industrial facility in the U.S. has a stormwater permit, as do many commercial and government entities. They all require training. Without it, compliance with your stormwater permit will be difficult at best, more likely almost impossible. And you know where non-compliance leads.
Do yourself a favor. Take a look into your stormwater training program. Chances are you’ll probably not be happy with what you find. If that’s the case, address that need today, for all employees. Trust me, you’ll be far better off.