Your engineer has delivered a Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) for your facility, and it requires that you train Oil-handling employees. Oil-handling employees? How do you determine which of your employees meet the definition of that term?
BACKGROUND
EPA’s SPCC regulation (found at 40 CFR 112.7) require that the owner or operator of a facility subject to SPCC regulations train all “oil-handling” personnel (see inset). No deviation from this requirement is allowed, even if your plan is signed by a Professional Engineer. For the purposes of this requirement, who is considered oil-handling personnel?
OIL-HANDLING EMPLOYEES
The term “oil-handling” personnel is not defined in the regulations, but EPA has clarified that the term can be interpreted according to industry standards. Oil-handling personnel include employees involved in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. This applies to both permanent employees and contractors.
Job titles that may be responsible for “oil-handling” include garage foreman, operations and maintenance, and mechanic. Employees with responsibilities that are solely administrative in nature (secretaries, clerks) and those who are not involved in operation or maintenance activities related to oil storage or equipment, oil transfer operations, emergency response, countermeasure functions are not considered oil-handling personnel.
TRAINING CONTENT
SPCC regulations allow for flexibility on training formats as it results in comprehension and understanding of the SPCC topics. The method of training should be specified in your SPCC Plan. Any format can be used (for example, classroom training or “tailgate” training). The regulations do not require a specific format, time length, or method, only that you get it done and include the following topics:
- Operation and maintenance of equipment to prevent discharges
- Discharge procedure protocols
- Applicable pollution control laws, rules, and regulations
- General facility operations
- The contents of the facility SPCC Plan
(Remember, SPCC training is different than stormwater training.)
TRAINING FREQUENCY
Oil-handling personnel must initially be trained when hired or assigned, when the facility changes, and when the SPCC Plan is amended. Every year thereafter, conduct annual SPCC briefings for these employees.
Determine which of your employees are oil-handling personnel and provide these employees training on the SPCC Plan. Provide training to new employees (or when employee duties change) and require that new employees work under the supervision of trained personnel until their training is complete.
DEMONSTRATING COMPLIANCE
It is important to document and maintain records of SPCC training to demonstrate the extent to which training requirements are met should an EPA inspector come to your facility.
While the SPCC regulations do not require oil-handling personnel to be tested on the SPCC plan or SPCC regulations, ensure that they have a good understanding of the SPCC plan. An EPA inspector would more than likely interview oil-handling personnel during an inspection to determine how familiar they are with the SPCC plan and how well they understand it. Should trained oil-handling personnel be unable to answer questions regarding the SPCC plan, the EPA could identify them as not being trained resulting in training violations at the facility.
Please contact EHS Management Strategies with any SPCC related questions or if we can help update or recertify your existing SPCC plan.
