By: Mike Arozarena
From implementing social distancing practices to organizing staggered work shifts and work-from-home policies, COVID-19 pandemic restrictions have certainly presented new challenges to businesses, resulting in new protocol and procedures to protect the health and safety of personnel. The ability to conduct required environmental, health and safety (EH&S) regulatory training is no exception, causing companies to wonder how they will be able to properly train employees, while also adhering to regulations. Storm Water Pollution Prevention Plan (SWP3) annual training Is a great example of one challenge companies will face.
Industrial Storm Water Training Requirements
Industrial storm water training requirements are described, in most cases, in state-issued National Pollutant Discharge Elimination System (NPDES) permits.[1] Some companies train all of their employees, however, you are only required to train staff who meet just one of the following criteria:
- Work in areas where industrial materials or activities are exposed to precipitation
- Are responsible for implementing activities necessary to meet permit conditions (e.g., inspections, maintenance personnel, housekeeping)
- Member of the pollution prevention team
The permit requires companies to train their staff annually on specific control measures and storm water monitoring, inspections, planning, reporting, and documentation requirements. The training program is not prescribed in the permit, so companies have flexibility in the content and method of training if the training program addresses the required content and achieves the goals specified in the permit.
Virtual SWP3 Training
During this COVID-19 pandemic, SWP3 annual training can be virtual! Since its inception in 2005, EHS Support has been a virtual EH&S consulting firm, with remote resources in place to support our clients. Our experienced scientists and engineers are well-versed in SWP3 regulations, and are well-positioned to provide remote training of your staff without the risk of unnecessary exposing personnel.
With some site specific input from you, we can tailor a SWP3 training program to your site to make the training presentation feel personal to your employees. We can include photographs of storm water outfalls, potential pollutant sources, and structural control measures to ensure the training is customized to the site.
Bottom line – EHS Support understands the current challenges of adhering to regulatory training standards and we are here to support you virtually.
For more information on conducting your SWP3 training virtually, contact Mike Arozarena today at 513-773-5364 or mike.arozarena@ehs-support.com.
[1] For example, in Ohio the industrial storm water Multi-Sector General Permit (MSGP), General Permit No. OHR000006 discusses annual training requirements in Section 2.1.2.9.
ABOUT THE AUTHOR Michael Arozarena has over 33 years of technical and project management experience in the environmental field. His diverse work background includes environmental consulting, private industry, and the U.S. Environmental Protection Agency Research Center. His areas of experience include plant-level regulatory compliance; EHS compliance audits; environmental permitting; stormwater and wastewater monitoring; aboveground storage tank testing; ambient air monitoring; and hazardous waste treatment technology evaluations… Read More
