EPA recommends that the training program be based on the U.S. Coast Guard’s (USCG’s) Training Elements for Oil Spill Response, as applicable to facility operations. An alternative program is also acceptable, subject to approval by EPA.
The owner or operator is responsible for the proper instruction of facility personnel in the response procedures to discharges of oil and in applicable oil spill response laws, rules, and regulations. The training must be functional in nature according to job tasks for both supervisory and nonsupervisory operational personnel.
FRP Training Requirements
The trainers must develop specific lesson plans on subject areas relevant to facility personnel involved in oil spill response and cleanup. Trainers should identify facility personnel responsible for performing specific procedures to mitigate or prevent a discharge or potential discharge and identify the response resources for worst-case discharges. Employees should be provided with a list of personnel who would be involved in the cleanup. Training records, such as drill logs, tabletop exercise logs, response training logs, and/or discharge prevention meeting logs, must be maintained and included in the FRP.
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In addition, the facility owner or operator must also develop a program of facility response drills and exercises, including program evaluation procedures. A program that follows the National Preparedness for Response Exercise Program (PREP) is satisfactory for purposes of this section. An alternative program may also be acceptable, on approval by EPA.
FRP Training Sample Quiz
The following is a sample quiz that an FRP trainer could provide to trainees.
1. Which EPA Region is this facility is located in?
2. What is name of this facility’s emergency response coordinator?
3. If the emergency response coordinator is not available, whom should you call?
4. T/F. Facilities with the potential to discharge oil into navigable waters are not required to have an SPCC Plan. (Answer: False)
5. T/F. To prevent spills, hoses, connections, and tanks should be inspected. (Answer: True)
6. T/F. My facility responds to all spills in the same manner whether they are small, medium, or worst-case spills. (Answer: False)
7. T/F. It is not necessary for me to personally know where emergency spill equipment is located or how to use it. (Answer: False)
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8. T/F. A visible sheet of oil on the surface of water may indicate a spill has occurred. (Answer: True)
9. T/F. A containment system to prevent an oil discharge must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs. (Answer: True)
10. T/F. Procedures for routine handling of oil products, such as loading/unloading procedures, are considered oil discharge prevention measures. (Answer: True)