Special Topics in Environmental Management

What the Regs Say About FRP Training

Operator Error Often the Cause of Oil Spills

Oil spill response training is an important element in EPA’s oil spill prevention and preparedness efforts. According to the EPA, a significant number of oil spills at facilities are caused by operator error, such as failing to close valves or overfilling tanks during transfer operations. Because operator error is often the cause of an oil spill, training and briefings are critical for prevention of a spill as well as response to a spill. Furthermore, proper training of facility personnel can reduce the severity of impacts when a spill does occur. Training encourages up-to-date planning for the control of, and response to, an oil spill and also helps to sharpen operating and response skills, introduces the latest ideas and techniques, and promotes interaction with the emergency response organization and familiarity with the facility’s Spill Prevention, Control, and Countermeasure (SPCC) and FRP plans.

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FRP Training in the Regs

Under 40 CFR 112.20(h)(8), FRPs must contain information about self-inspection, drills/exercises, and response training, including descriptions of training and drill/exercise programs and documentation of tank inspections, equipment inspections, response training meetings, response training sessions, and drills/exercises. Consequently, FRPs may be revised on the basis of evaluations of the facility drills and exercises.

Section 112.21 of the Oil Pollution Prevention Regulation requires the development and implementation of facility response training programs. It is recommended that the training program be based on the U.S. Coast Guard (USCG) Training Elements for Oil Spill Response, as applicable to facility operations. An alternative program can also be acceptable, subject to approval of the regional administrator. The training must be functional in nature according to job tasks for both supervisory and nonsupervisory operational personnel. Trainers must develop specific lesson plans on subject areas relevant to facility personnel involved in oil spill response and cleanup.

See this FRP Sample Training Quiz.

The requirements for oil spill response training and response drills and exercises are codified at 40 CFR 112.21 for facilities that are required to prepare an FRP.

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National Preparedness for Response Exercise Program (PREP)

Under 40 CFR 112.21, facilities are also required to develop and implement a program of response drills and exercises, including evaluation procedures to test the effectiveness of their response plan. A program that follows the National Preparedness for Response Exercise Program  will meet these requirements. An alternative program can also be acceptable if approved by the regional administrator.

The USCG, the EPA, OPS, MMS, states, and industry developed PREP. The program consists of notification, tabletop and deployment exercises that are both announced and unannounced, as well as participation in larger area drills that exercise the appropriate ACP. Exercises that involve other members of the response community outside of the facility include industry- and government-led area exercises and government-initiated unannounced exercises. These exercises are designed to evaluate the entire response mechanism in a given area to ensure adequate preparedness. The goal of PREP is to conduct approximately 20 area exercises per year. PREP also includes a schedule for the exercise of facility FRPs over a 3-year cycle.

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