Recently we covered the required annual OSHA safety training requirements your company should be scheduling each year. What about the most common annual EPA or environmental training requirements?
RCRA Hazardous Waste
Training is required for anyone handling or managing hazardous waste. For large quantity generators this training is required annually by federal regulations. For conditionally exempt small quantity generators and small quantity generators, annual training is not specified in the federal regulations but is considered a best practice.
Many states have their own hazardous waste regulations which can vary from the federal version and even be stricter, so be aware of the regulations for your area. For example, in Kansas, small quantity generators are specifically required to have annual training.
Stormwater Pollution Prevention Plan (SWP3)
Training is required annually for any facility required to have a Stormwater Pollution Prevention Plan, and in some locations, additional training may also be required. iSi did a stormwater training project for a client who had facilities in 48 states, and one of the modules we produced had a clickable state map where the learner could go learn about the rules for their state. In our research, we found stormwater rules can vary greatly from state to state, and in some cases, from municipality to municipality. State general permits have expiration dates on them and will be updated when the new one is issued, so check with your state’s environmental agency and find their general permit to see what the rules are.
[Don’t have time to look it up? Contact us and we can get you pricing to have one of our environmental team members look up the most recent permit for your state(s) and determine what your requirements are, and what your training needs to cover. (We can do the training too or make the slides for you if you need it.)]
Spill Prevention, Control and Countermeasures (SPCC)
Any company required to have an SPCC Plan must conduct training annually. SPCC Plans ensure facilities have containment and other countermeasures in place to prevent oil spills from reaching navigable waters. Annual training is required for oil-handling personnel to ensure the prevention measures and procedures are in place, understood and followed. This training should include the procedures and policies written in your SPCC plan.
Facility Response Plan (FRP)
FRPs are plans regarding oil spill responses after the spills occur. For those who are required to have FRPs in accordance with 40 CFR Part 112, there is training required as well as hands-on exercises. The National Preparedness for Response Exercise Program (PREP) is to be used for the hands-on portion and the U.S. Coast Guard’s Training Elements for Oil Spill Response can be used for the classroom training.
Qualified individual and emergency procedures exercises must be conducted quarterly, equipment deployment exercises must be conducted semiannually, and incident management team tabletop exercises must be conducted annually. There are additional requirements for unannounced and after business hour training.
This is different from HAZWOPER, which is an OSHA requirement, but you could incorporate some of the exercises as part of your annual HAZWOPER training.
Those certified as asbestos workers, contractor/supervisors, inspectors, planners and project designers are required to complete annual refresher training.
On the OSHA side, maintenance personnel who may disturb asbestos within the course of their duties are required to have annual awareness training. Although EPA addresses awareness training for these workers, it’s OSHA that requires the training annually.
Others Worth Mentioning
TSDF facility personnel must have RCRA emergency response training, and that training can be HAZWOPER if it meets the RCRA requirements. HAZWOPER refresher training is due annually.
There are other annual environmental training requirements for industrial processes which are not as widespread including municipal solid waste combustors, medical waste incinerators, and underground hazardous waste injection wells. Much of this training is also conducted by EPA or state-approved training providers.
Others Required, but Not Annually:
- NESHAP Subpart HHHHH (6H) for Paint Stripping and Surface Coating Operations: Every 5 years
- Risk Management Plans: Every 3 years
- Pesticides: Every 5 years
- Lead-Based Paint (Lead Renovation, Repair and Painting Rule (RRP)): Every 3-5 years depending on the initial test you took
- DOT (for hazardous waste manifest signing): Every 3 years
- IATA (for air shipments of hazardous materials): Every 2 years
- IMDG (for vessel shipments of hazardous materials): Every 3 years