Monday, December 22, 2008

Stormwater Training – Do I Need To Train Contractors?

The question is often asked – does a permitted facility need to provide Stormwater Pollution Prevention Plan Training (“SWPPP training”) to contractors working on-site?

The answer is in the form of another question – Can the contractor’s actions result in violation of permit conditions and/or non-conformance with the stormwater pollution prevention plan? If yes, then providing some level of training to contractors will be in the facility’s best interest. This training may not necessarily be the same SWPPP Training given to employees. [Read more about contractors and maintaining compliance] [What kind of SWPPP Training is required?]

Requirements for training in State general permits typically refer to employee training only and do not expressly address contractors. However, as the permit holder, the facility has the ultimate responsibility to meet requirements of the permit. Whether violations are caused by the facility employees or by contractors working on site, the result may be the same and the facility could ultimately be held responsible.

Some form of contractor training is likely already occurring. Other regulatory programs, such as the OSHA hazard communication standard, require some level of contractor training. Facilities with an environmental management system (EMS) conforming to the ISO 14001 standard are required to provide training to contractors. Therefore, incorporating SWPPP Training into existing contractor training procedures can be done with very little additional effort.

Caltha LLP provides technical support to develop all required SWPPP Training programs, as well as other environmental training and contractor training programs.

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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