Ecology believes that employee training is critical to compliance with the conditions and requirements of the sand and gravel general permit. The permit requires that all employees receive training to assure all spills are reported and responded to appropriately, however, all employees should also receive training on the monitoring requirements and BMPs. If Ecology observes during inspection that BMPs are not being properly implemented, a formal training plan, to be placed in the SWPPP, may be required. If required to develop and implement an employee training plan the permittee should consider the following elements.
Best management practices (BMPs): BMPs are a major requirement of the sand and gravel general permit. A training plan should identify all the BMPs applied at a facility, what employees have primary responsibility for applying and maintaining these practices, and what other employees should know to assure the success of these BMPs.
Example: The training plan may identify as a BMP a berm that prevents Type 2 stormwater from entering the active mine site. The site manager may then be identified as the person responsible for creating and maintaining the berm. While training for the site manager may be obvious, all other employees should also receive training on the purpose of the berm and reporting any observed breach of that berm.
The training plan should also identify how employees will receive training. Will there be written material for employees? Will the employees receive verbal instructions, view videos? When will new employees receive training and when will existing employees receive a refresher course? Will employee training include a test on training effectiveness?
All employees shall receive appropriate training to assure that spills are reported and responded to appropriately. (Permit Special Condition S5.D.3.)
A permitted facility has most likely invested time and money to provide physical protection against spills of materials that could harm the environment. Equally important is the protection afforded by well trained employees. Employees must know the procedure for reporting a spill. If they are expected to initiate a response they require training in that response. Employees should know where spill response materials are kept and the importance of maintaining ready access to these materials.
Employees are a tremendous resource. They will cover all parts of the site in the course of their duties. If they are trained to look for and report problems or potential problems, they become a major component of the spill prevention and cleanup strategy.
Employees that understand the goals and responsibilities of the permit help ensure successful permit implementation and compliance. It makes them a part of the process and can have the beneficial side effect of increased morale. Training should include information on:
- What monitoring is required.
- What permit limits apply to the site.
- How do you accomplish good housekeeping onsite?
- Why environmental protection is good business.
Training should cover the permit monitoring requirements. The permit has different requirements based on what type of water is discharged. Employees should know that process water is any water that comes into direct contact or results from the production or use of any raw material or product. They should know that process water is generally considered to have a greater potential threat to the environment and therefore the permit requires more monitoring of process water. Informed employees can help assure that pollution prevention measures succeed, suggest creative ways to improve water management onsite, and alert managers to potential problems.
Perhaps the most important part of the training will be providing the employee with the understanding that they are an important part of providing environmental protection and compliance with coverage under the sand and gravel general permit. There are two key elements to employee participation:
- Employees must know how and to whom they can report problems and solutions. Employees should be encouraged to become active players in permit compliance.
- Employees need to know that their actions matter. Spilling even small amounts of petroleum on the ground can add up over time. Knowing the importance of pollution prevention and maintaining a clean site changes the way employees act. Environmental protection is a learned behavior.
The precise content of training must be tailored to the specific conditions at the site. The number of employees, the complexity of the site, and how the facility achieves compliance with permit coverage all make a difference in what information training must include. However, all training should include the following elements:
- Provide the employees with an overview of permit requirements and actions the facility takes to comply with the permit.
- Identify the best management practices that have been implemented at the facility. In addition to specific instructions for those with primary responsibility for BMP maintenance, make sure all employees understand the purpose and mechanism for each BMP.
- Detail specifics on spill response and reporting. All employees must know what they are to do if they observe a spill.
- Emphasize the importance of employee participation. Employees must feel that they are a part of environmental protection and that their employer believes it is an important part of doing business.
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