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