What Are the Training Program Requirements?
- Training must be functional according to job tasks for both supervisory and non-supervisory employees.
- Lesson plans must be developed for specific subject areas relevant to facility personnel involved in oil spill response and cleanup.
- Facility owners and operators must develop a program of facility response drills and exercises, including evaluation procedures.
- Training records must be retained for a minimum of 3 years.
Who Has to Be Trained?
There are a variety of employees within an organization that must be trained in facility response procedures. Different types of training must be performed for different employees. For example, workers with spill clean-up responsibilities need to be trained to deploy and operate equipment they will actually use during a response. Supervisors should be trained in response management strategies and spill forecasting.
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These are the categories of employees that must receive training:
Qualified Individuals. A qualified individual is the point of contact between the federal government and the owner or operators of the facility of facility.
Spill Management Team. A spill management team must be described in the FRP. Team members assist or relieve the company’s qualified individual in the actual response to an oil or hazardous substance spill, and should be trained according to their functional role within the response organization.
Vessel Personnel. Vessel personnel are all employees that work on a vessel. These employees should receive both oil spill prevention and response training specific to the handling and storage of oil on a vessel.
Facility Personnel. All oil-handling personnel at a facility must receive prevention training focusing on the operation and maintenance of equipment and the facility’s Spill Prevention, Control, and Countermeasure (SPCC) plan. Response training must also be conducted.
Oil Spill Removal Organizations (OSROs). Federal regulations require owners and operators of tank vessels and facilities to ensure, through contracts or other approved means, sufficient private resources to remove specific volumes of oil. Employees of OSROs identified in an FRP must be trained, and such training must be documented. OSRO employee training generally does not have to be as thorough as that provided to vessel and facility personnel
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FRP Training Checklist
(Specifically for Qualified Individuals, Spill Management Team Members, and Vessel and Facility Personnel)
Have your employees received sufficient training to demonstrate knowledge of:
__ Captain of the Port Zones or EPA Regions in which the vessel will operate or the facility is located?
__ Notification procedures and requirements for vessel or facility owners or operators; internal response organizations; federal and state agencies; and contracted oil spill removal organizations and the information required for those organizations?
__ Communication system used for the notifications?
__ Information on the cargoes carried by the vessel or transferred, stored, or used by the facility, including familiarity with MSDSs, special handling procedures, health and safety hazards, spill and fire fighting procedures?
__ Procedures the crew or facility personnel may use to mitigate or prevent any discharge or substantial threat of a discharge of oil resulting from shipboard or facility operational activities?
__ Vessel crew or facility personnel responsibilities, and procedures for use of shipboard or facility equipment that may be carried to mitigate an oil discharge?
__ Operational capabilities of the contracted OSROs to respond to small discharges, maximum most probable discharges, and worst case discharges?
__ Responsibilities and authorities of the qualified individual as described in the facility response plan?
__ The organizational structure that will be used to manage the response actions, including command control, public information, safety, liaison with government agencies, spill response operations, planning, logistics support, and finance?
__ The responsibilities and duties of each oil spill management team member?
__ The drill and exercise program?
__ Responsibilities associated with the post-discharge review of the FRP to evaluate and validate its effectiveness?
__ Applicable Area Contingency Plans (ACPs) and the National Contingency Plan (NCP)?
__ OSHA requirements for worker health and safety?
__ Incident Command System/Unified Command System?
__ Oil spill trajectory analyses and crisis management?
In tomorrow’s Advisor, we tell you how to write really good lesson plans for your FRP training program.