Annual SPCC Training – what is required?

As an auditor, the requirements for annual SPCC training are often not well defined and not well implemented.  40 CFR 112.7(f) specifies the requirements for annual briefings to review the SPCC with “oil-handling” employees. This briefing is NOT simply generic spill training for cleaning up oil spills but a review of ALL components of the SPCC with employees engaged in oil-handling and those we would expect to respond to a spill.

40 CFR 112.7 (f) Personnel, training, and discharge prevention procedures.

(1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan.

(2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.

(3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in § 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures.

This training program can easily be completed in a ½ hour and should include:

  1. Reminder of where SPCC Plan is stored and very brief overview of SPCC rules
  2. Review oil handling procedures including loading / unloading procedures
  3. Review locations of drains and storm sewers that need to be protected
  4. Discuss any spills in past 12 months – minor & major
  5. Discuss roles & responsibilities for spill response
  6. Review spill response procedures and locations of spill response materials

Be sure to document the training to include – materials reviewed and employees name and title.

For facilities that are ISO 14001 certified this training is also the best time to stage a “spill drill”.  This can be as simple as developing a likely spill scenario and reviewing response actions with the team. An example would be to take the team to the shipping dock and give them a scenario – “a truck just pulled in, is leaking diesel, and it is flowing towards the drain – how do we respond?”. You then step through the process and document this in a memo format as a spill drill. Your ISO auditor will be impressed.

Please contact us if we can help you develop your SPCC training program or deliver the training.


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