Wednesday, November 26, 2008

SWPPP Training Videos and Stormwater On-line Training - Do These Resources Meet Requirements?

Many good training resources are available, including video training and “on-line” courses. Caltha often recommends these resources as an element of a facility’s training program.

Whether or not these types of “off-the-shelf” training resources meet the training requirements will depend on the specific requirements for your State. In many cases, training needs to include information on the facility SWPPP, and therefore the “off-the shelf” resources need to be augmented with facility-specific training.

For example, here is an excerpt from a State permit that specifies training requirements:

Texas (TCEQ) General Permit:
Employee Training Program and Employee Education: A section within the SWP3 shall be
developed to establish a training program. Training shall be provided to all employees who are
responsible for implementing or maintaining activities identified in the SWP3. Employee training
shall include, at a minimum:
(1) proper material management and handling practices for specific chemicals, fluids, and other materials used or commonly encountered at the facility;
(2) spill prevention methods;
(3) the location of materials and equipment necessary for spill clean up;
(4) spill clean up techniques;
(5) proper spill reporting procedures; and
(6) familiarization with good housekeeping measures, BMPs, and goals of the SWP3.

...Education must be provided to those employees at the facility who are not directly responsible for implementing or maintaining activities identified in the SWP3, and who do not participate in the employee training program. At a minimum, these employees must be informed of the basic goals of the SWP3 and how to contact the facility’s storm water Pollution Prevention Team regarding storm water issues.

This this case, generic training materials would need to be supplemented with site-specific information on the facility's stormwater pollution prevention plan and site specific controls and procedures. Even the basic "awareness" training required for all employees needs to be site-specific.

Click here for more information on State-specific SWPPP - Stormwater Training Resources.

For further information contact Caltha LLP at
Caltha LLP Website

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