In this Environmental Daily Advisor transcript, Advisor editor Kelly Lagana talks with Amanda Czepiel about required training for EPA’s Spill Prevention, Control, and Countermeasure (SPCC). Amanda Czepiel is legal editor for BLR’s environmental compliance products.
KL: Hi everybody this is Kelly Lagana. I’m with BLR’s Environmental Daily Advisor. We’re talking today to Amanda Czepiel. She’s our SPCC legal editor for our environmental compliance products. Thank you for joining us today.
SPCC is one of the most popular topics on Enviro.BLR.com, if not the most popular topic. I don’t have to tell you it’s the topic that we get the most expert questions about from our subscribers.
AC: Yes, by far.
KL: What I wanted to do was talk about SPCC, specifically training, but first of all, if you could just tell everybody what is SPCC?
AC: Sure. It’s a federal regulation – SPCC stands for Spill Prevention, Control, and Countermeasure (SPCC). The goal is to prevent pollution of navigable waters from oil. It’s training, planning, and a set of protocols of what to do in terms of a discharge.
KL: What are the facilities that must have employees trained on SPCC regs?
AC: Facilities that are regulated under SPCC are facilities that store or handle oil, above ground 1,320 gallons, or 42,000 gallons underground. And that’s a capacity requirement. It’s not how much oil you have on site, but how much oil you can have on site.
The second component in that threshold is whether if you have a discharge in your facility, whether that spill can reach navigable waters. That’s kind of a gray area sometimes because people think “My facility is in the middle of nowhere in the desert, how could it ever reach navigable waters?”
KL: But it can.
AC: It can. The definition of that is very wide. It’s basically if it can hit a stream, it can hit a navigable water, and you are covered. Better safe than sorry with that one.
KL: Let’s say you’re a regulated facility. Who in that regulated facility needs to be trained? What are the types of employees that need to be trained?
AC: It’s again, pretty far-reaching. It’s any employee that handles oil in some kind of capacity. That also includes contractors.
KL: So that could be a lot of people.
AC: Right. If you have someone in a contract basis, subcontract basis, they need to be trained as well as your full- and part-time employees on site.
KL: If I were to put together an SPCC training program, what should the goals be? What should I try to achieve?
AC: You really want the employees to know first of all what is the SPCC plan? It’s something that day to day – an employee doesn’t deal with regulations day to day. You really want to let the employees know why they’re in that training and what the goals are of SPCC, because it doesn’t seem to be pertinent day to day.
KL: That’s very important I think with all training.
AC: Exactly, people need to care what they’re doing.
KL: But first thing’s first.
AC: And then you really want to describe what your facility does according to the SPCC plan. Describe what your secondary containment is for your oil handling and storage facilities. Also with the second containment you want to describe what can go wrong with the second containment. Obviously second containment is there to stop the discharge of oil into navigable waters. But it’s not perfect. Things get clogged, so you want to teach good housekeeping: how to clean out drains, how to maintain things, that kind of thing.
You also want to describe what security measures you have on site so your employees keep a watch out if something’s not particularly correct. There’s lighting responsibilities under SPCC, fencing in some cases, signage. You really want your employees to know what to watch out for to prevent something from going wrong. If there is a spill, there’s so much more to do. It’s better to prevent.
KL: It’s the “P” in SPCC.
AC: You don’t even want to get into the “Control” part. You really want to stay at the “P.”
KL: Just one last question. How often do these employees have to be trained? What’s the training frequency?
AC: All new employees should have a full training as soon as they are hired and onsite. The entire SPCC plan should be covered. Existing employees should be debriefed once a year. You don’t have to do a full training but you should really cover if there’s any changes to your SPCC plan, any changes to secondary containment, if you have more oil or less oil onsite. Basically this is an update, but it should be also comprehensive.
KL: And that’s annually.
AC: Right. And that’s annually.
KL: Ok, excellent. Well, that’s all the questions I have for you today. Thanks so much for joining us.
AC: Thank you.