1. Who is required to be trained?
a. All oil-handling personnel only
b. Only personnel who inspect tanks
c. Personnel who work with tanks holding 10,000 gallons or more
d. All facility employees
Correct Answer: a
All oil-handling personnel must be trained in the operation and maintenance of equipment to prevent the discharge of oil. Keep in mind, oil-handling personnel includes contractors as well as permanent employees.
2. At a minimum, how often are you required to train workers?
a. Only when there are new oil-handling employees
b. Once per year
c. Once every 5 years
d. SPCC regulations do not require you to train workers regularly
Correct Answer: b
Spill prevention briefings must be conducted at least once per year to ensure understanding of your facility’s SPCC Plan. The briefings must highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures.
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3. Oil-handling personnel must be trained on:
a. Discharge procedure protocols
b. Applicable pollution control laws and rules
c. General facility operations
d. The contents of the facility’s SPCC Plan
e. All of the above
Correct Answer: e
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According to 40 CFR 112.7:
Personnel, training, and discharge prevention procedures. (1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan.
4. EPA requires you to formally test your workers on SPCC knowledge and keep records of scores.
True
False
Correct Answer: False
SPCC regulations do not require you to formally test workers on SPCC knowledge. However, it is good idea for you to make sure that your workers understand your SPCC training. An EPA inspector will typically talk to field workers during an inspection to test the depth of their understanding of your SPCC training. Workers who can’t speak to the specifics of the SPCC plan at your facility could be deemed not trained by EPA and subjecting your facility to training violations and fines.
And while there are no provisions that require recordkeeping of SPCC training, maintaining records of SPCC training provided will help demonstrate the extent to which training requirements are met.
5. You can use any method or format to train workers on SPCC.
a. True
b. False
Correct Answer: True
Trainers have flexibility on training formats. Trainers may use hands-on demonstration, classroom, and any other method of training that leads to comprehension and understanding of the topic. There should be an opportunity for trainees to ask questions and receive answers from the person conducting the training session.
See tomorrow’s Advisor for a training checklist to help you get started with an SPCC training program.