As required by Federal Regulation 40CFR112 (aka the SPCC Rule), SPCC Plans must specify Engineering and Administrative controls and procedures that prevent or minimize oil/fuel releases, leaks and/or spills onto the ground and potentially into a nearby Navigable Water or drainage thereof. One key administrative control is the ANNUAL TRAINING of oil-handling personnel. 40CFR112.7(f) specifically requires that “At a minimum, train your oil-handling personnel … discharge prevention protocols; applicable pollution control laws, rules and regulations … and the contents of the facility SPCC Plan.”
Who Are Oil-handling Personnel?
Oil-handling personnel are the salt of the Earth! They’re the hard-working, behind-the-scenes employees at the leading-edge of a facility’s operations that frequently involve the environmentally-sensitve transfer of oils and fuel, the ongoing handling and maintenance of oil / fuel storage containers and tanks, as well as being the initial onsite responders to facility leaks, releases and/or spills.
Improperly trained oil-handling personnel get hurt more often and inadvertently allow unnecessary leaks, releases and/or spills to occur at their facility. In my numerous facility inspections, I’ve found almost every oil-handling employee to genuinely care about the environmentally-safe operation of their facility, as they often take considerable personal pride in the critical function they have in properly running and maintaining the facility. As said above, oil-handling personnel are indeed the salt of the Earth!
This 8-hour workshop guides key oil-handling personnel through the otherwise confusing maze of regulatory text and helps them better understand their SPCC Plan, so that a future EPA inspection will only be a formality and NOT a bad dream (see http://e-c-associates.com/spill-compliance-news/)! As stated in the regulatory citation (see Background), oil-handling personnel must get annual training that addresses the follow areas:
Proper operation / maintenance of oil/fuel-transfer equipment and storage containers / tanks
Proper discharge prevention protocols
Refresher on applicable pollution control laws, rules and regs like 40CFR112
Refresher on the contents of their facility’s SPCC Plan
In Closing …
When the EPA Inspector visits your facility, s/he will probably talk with the facility’s oil-handling staff, to determine just how well they understand the facility SPCC Plan. If such interviews reveal improperly trained oil-handling personnel, the EPA could cite the facility with a Training Violation (see http://e-c-associates.com/spill-compliance-news/)!
Annual training by facility management or by designated well-trained oil-handling personnel orby third-party experts such as ECA, is critical, because it 1) eliminates regulatory violations and fines, 2) greatly enhances every employee’s safety (we all want to go home every night!) and 3) significantly improves facility housekeeping and protects stored oil/fuel inventories!