Annual Employee Training (On Site)

The EPA requires that every operator that implements a SPCC Plan also train every field officer and agent that would walk onto the facility. This includes pumpers, owners, and day-to-day operators. The training is not something that is complex, but it must cover the basics of the 40 CFR 112 and 109.

Many companies have their own training manuals which is fine. The EPA doesn't look very closely at the training material, but they do review to see if it covers the basics. Some companies will print the entire CFR Code 40.112 and 109 and use that for their training, which is fine. However, the most important part of implementing the company-training is that you document with dates and signatures all those who particiate.

Most spill plans will have a page to mark all the names and signatures for this. You could go online and buy training online, but it is certainly not necessary. The EPA doesn't require fancy training, however it's a good business practice to make sure your agents and officers correctly know how to handle a spill or spill response situation. The online trainings are not expensive and are a great idea.

Before you buy a spill plan from a company make sure to ask if they include the Training References in the plan, which is required by the EPA that a company document in writing that their people are trained at least annually in accordance with the written SPCC Plan.