Wednesday, December 24, 2008

Knowledge Based SWPPP Training – Texas (TCEQ) Construction Permit Example

Stormwater training requirements in most general permits are prescriptive and require specific documentation to demonstrate compliance. If documentation can be produced that shows an employee received appropriate training, the permit requirement is considered to be met. Most often, training rooster sign-in sheets are used as documentation.

An alternate requirement for SWPPP training is “knowledge-based”, meaning that compliance or noncompliance is determined by what the employee knows and not what training courses the employee has attended.

An example of knowledge-based training requirements is found in the Texas Commission on Environmental Quality (TCEQ) general permit for construction stormwater discharge (Permit # TXR150000). In this permit, “training” is only required for personnel responsible to conduct site inspections. No specific training needs to be documented. However, inspectors must be “knowledgeable of [requirements of the] general permit, familiar with the construction site, and knowledgeable of the SWPPP for the site”. Regardless of any specific training inspectors can show, if they can not meet these performance criteria, they may not be considered qualified to conduct inspections.

Although knowledge-based training requirements have the advantage that no specific training documentation is needed, they also require a higher standard for actual knowledge. Employers need to assure that their employees know what they need to know.

Caltha LLP has several training programs created to help Texas contractors meet the performance standards of the TCEQ construction site discharge permit, including several customized programs to meet the requirements of small and medium size contractors in all States.

For further information contact Caltha LLP at
Caltha LLP Website

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