SPCC Employee Training Required for Compliance
You’ve developed and implemented a Spill Prevention, Control, and Countermeasure (SPCC) Plan that meets all federal SPCC regulatory requirements. You’ve put into action an inspection program that is well documented in your Plan, and you’ve made sure that all secondary containment is sufficient to prevent an oil discharge to navigable waters and adjoining shorelines. It sounds like your facility is fully compliant with the SPCC regulations, right? But unless you have implemented a training program and are routinely training new and existing oil-handling personnel, you are not fully in compliance.
SPCC plans are a cornerstone of the U.S. Environmental Protection Agency’s (EPA) strategy to prevent oil spills from reaching U.S. waters. Unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, SPCC plans ensure that facilities put in place containment and other countermeasures that would prevent oil spills from reaching navigable waters. In order for spill prevention, containment, and countermeasures to work properly, employees must be trained to ensure the measures are installed, operated, and maintained.
The SPCC regulations require that all oil-handling personnel at SPCC-regulated facilities be trained. “Oil-handling personnel” is interpreted according to industry standards, but includes employees engaged in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. Oil-handling contractors at a facility must be trained as well as permanent employees.
SPCC training should include:
• An overview of the SPCC regulations and related pollution prevention regulations
• Oil storage, transfer, and handling equipment on-site, including secondary containment
• Secondary containment failures and what conditions require a spill report
• Security measures on-site and description of potentially suspicious situations
• Discharge procedure protocols and expectations of first responder actions
After SPCC training, employees should be expected to:
1. Explain the reason for the SPCC Plan
2. Follow proper containment practices for oil storage
3. Describe causes of secondary containment structure failures and explain the
importance of limiting rainwater and debris in structures
4. Describe problems and or conditions that should be reported
5. Follow safety procedures and list the facilities security features
6. Follow appropriate discharge procedures and identify the first step to take when a
spill, release or leak is discovered
Trainers may use hands on demonstrations, classroom and any other method of training that leads to comprehension and understanding of your facility’s SPCC Plan and how it is implemented. There will be opportunities for trainees to ask questions and receive answers that are compliant with regulatory requirements and your Plan.
When preparing for a training session, the presenter will have the following material available for review by the employees:
· A copy of the current SPCC Plan and the Facility Response Plan (FRP)
· Copies of your facility’s Emergency Response Action Plan
· Copies of facility’s diagram
· Examples of spill control equipment your facility has available on-site
· Handouts to reinforce training
Trainers are knowledgeable in the subject matter covered by the elements contained in the training program generally and as it relates specifically to the facility that the training is for. Trainer will be well qualified to implement the components of the SPCC and FRP that will be addressed in the training session. Although not required, a licensed professional engineer conducts most of the training sessions provided by Quest Consultants.
Spill prevention briefings must be conducted at least once per year to ensure understanding of a facility’s understanding and compliance of your SPCC Plan. The briefings must highlight and describe known discharges or failures, malfunctioning components and any recently developed precautionary measures. Training needs to be conducted whenever there is a change in your SPCC Plan, a discharge occurs at the facility, new equipment is added, containment is changed or modified or when personnel changes occur.
A training session is successful only if objectives are met. After training, the following questions need to be addressed to ensure that all content areas were adequately covered and that all attendees received and understood all necessary information. Training records should of course be maintained by the facility.
· Are employees familiar with spill prevention procedures?
· Are employees familiar with spill prevention and control equipment used at the facility?
· Does the facility have written procedures for inspecting and testing oil spill contamination containment systems?
· Have appropriate personnel been properly trained and instructed in the operation and maintenance of equipment and tools to prevent the discharge of leaks releases or spills?
· Do the employee’s know how to contact the facility’s emergency response coordinator?
· Do employee’s know the facility’s notification procedures and communication system to be used for notification?
· Are employees certain of their duties and responsibilities in the event of a spill?
· Do employees know the procedures to mitigate or prevent any discharge or substantial threat of a discharge or spill?
· Have you pointed out the location of all spill response equipment and is is marked in accordance with SPCC Federal compliance requirements?
· Is the spill response equipment easily accessible and in good working order?
· Who is responsible for frequent inspections of spill control systems and equipment as required by Federal SPCC regulatory record keeping requirements?
· Do employees know their duties in the event of a shutdown?
· Do employees know their duties regarding equipment start-up after a power outage?
· Have records been maintained od completed SPCC training exercises as specified under SPCC requirements?
· Are training logs maintained at the facility for drills, exercises and response training?
SPCC regulations do not require you to formally test employees on SPCC knowledge. However, it is considered a valuable BMP (Best Management Practice) and it is a good idea for management to make sure that your workers understand your SPCC and receive proper training per regulatory requirements. An EPA inspector will typically talk to field workers during an inspection to test the depth of their understanding of your SPCC training at your facility. Employees who can’t speak to the specifics of the SPCC Plan at your facility could be deemed not trained by the EPA and could subject your facility to training violations and fines.
Maintaining records of SPCC training will help demonstrate the extent to which your company meets training requirements. If you need help in setting up these records, please call Quest Consultants.
And if you don’t train?
EPA inspectors are now trained to notice. Not creating a training program and failing to properly train oil-handling personnel can result in fines, even if a discharge does not occur.
If you would like us to provide a proposal to provide proper regulatory training to personnel, please call us at 888-730-4646