OKR05 Employee Training Requirements

OKR05 Stormwater Industrial Permit Workshop

28th Resource Management Conference

Tulsa Garden Center

March 26, 2015

2INCOG

Storm Water Pollution Prevention Plan (SWP3) Training Requirements

Part 4.2.8.1.F

“Employee Training: You must describe the storm water employee training program for the facility.”

This should include topics such as:

Spill response

Good housekeeping

Material management

Necessary safety gear

3INCOG

Spill Response

Stop the spill

Container leaks: Right the container or, for a puncture, use epoxy putty, patching paste or drum patch kit.

Pipe leaks: Close a valve or use a pipe wrap or repair kit.

Aluminum or another type of patching tape or even a screw might make an acceptable temporary patch.

4INCOG

Spill Response

Contain the Spill

If the container is on a containment pallet or in another vessel, you have it.

Use absorbents, socks, booms or covers to keep the spilled material out of inlets and waterways.

Protect the spilled material from tracking (boots, tires), wind dispersion or flowing to other areas.

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Spill Response

Remove the Material

Think about how you can recover the material and what you will put it in. Will you dispose it or can you still use it?

Do you have empty containers, shovels, brooms or vacuum pumps?

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Spill Response

Remediate the Site

How will you clean up the spill site and what might you do to prevent another spill of this nature.

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Good Housekeeping

“You must keep all exposed areas of the facility in a clean, orderly manner where such exposed areas could contribute pollutants to storm water discharges. Common problem areas include: around trash containers, storage areas and loading docks.”

Do your employees know how to keep a clean shop?

8INCOG

Material Management

“You must minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff by either locating these industrial materials and activities inside or protecting them with storm resistant coverings (although significant enlargement of impervious surface area is not recommended).”

Do your employees know how to use, store and manage materials?

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Personal Protection (Safety Gear)

If personal protection is necessary to safely handle the chemicals, materials or products that could cause storm water pollution at your facility your employees should be trained in the proper use of the safety gear.

10INCOG

Training Frequency

Part 4.2.8.1.F

“…and must identify periodic dates (e.g., every 6 months during the months of July and January) for such training.”

“Such training shall be conducted at least annually (or more often if employee turnover is high.)”

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Training Frequency

To meet the training frequency requirement you may elect to have two training programs.

Training update events

New hire training program

The new hire training would be to explain the OKR05 requirements to new employees so they are knowledgeable from the beginning and the updates will keep all employees familiar with company policies and changes to these policies.

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Who Needs Training?

Part 4.2.8.1.F

“You must provide employee training for all employees that work in areas that are responsible for implementing activities identified in the SWP3 (e.g., inspectors, maintenance people).”

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Retention of Records

Part 7.1.2

“Your must retain the SWP3 developed in accordance with Part 4 of this permit until a date three (3) years after the last modification or amendment is made to the plan, and at least three (3) years after coverage under this permit terminates.”

All training activities should be documented and recorded.

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Sector Specific Requirements

Certain industrial sectors have special concerns due to specific activities and/or

chemicals or materials they use in a process.

Following are some sectors that have specific training and education requirements.

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Automobile Salvage Yards (12.M.3.5)

“Employee Training. (See also Part 4.2.8) If applicable to your facility, address the following areas (at a minimum) in your employee training program: Proper handling (collection, storage, and disposal) of oil, used mineral spirits, anti-freeze, mercury switches and solvents.”

16INCOG

Scrap Recycling and Waste Recycling Facilities 12.N.4.2.A(d)

Inbound Recyclable and Waste Material Control Program

“(d) provide training targeted for those personnel engaged in the inspection and acceptance of inbound recyclable materials;…”

This is intended to “Minimize the chance of accepting materials that could be significant sources of pollutants by conducting inspections of inbound recyclables and waste materials.”

Be aware of things like lubricating fluids, mercury switches, heavy metals and battery acids.

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Scrap Recycling and Waste Recycling Facilities 12.N.4.2.F(e)

Scrap Lead-Acid Battery Program

“(e) provide employee training for the management of scrap batteries.”

Employees need to know how to properly handle, store, and dispose of cracked, broken or leaking lead-acid batteries and battery fluid.

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Scrap Recycling and Waste Recycling Facilities 12.N.4.4.A(b)

Inbound Recyclable Material Control

“…(b) training drivers responsible for pickup of recycled material:…”

This is for recycling facilities that receive source-separated materials primarily from non-industrial and residential sources. The intent is to minimize the amount of inappropriate material the facility receives for recycling.

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Scrap Recycling and Waste Recycling Facilities 12.N.4.4.C(c)

Indoor Storage and Material Processing

“…(c) provide employee training on pollution prevention practices.”

This is for recycling facilities that receive source-separated materials primarily from non-industrial and residential sources.

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Scrap Recycling and Waste Recycling Facilities 12.N.4.4.D(g)

Vehicle and Equipment Maintenance

“…(g) provide employee training on proper handling and storage of hydraulic fluids and lubricants.”

This is for recycling facilities that receive source-separated materials primarily from non-industrial and residential sources.

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Land Transportation and Warehousing 12.P.4.5

Additional SWP3 Requirements

This applies to:

Railroad Transportation

Local and Highway Passenger Transportation

Motor Freight Transportation and Warehousing

United States Postal Service

Petroleum Bulk Stations and Terminals

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Land Transportation and Warehousing 12.P.4.5

Additional SWP3 Requirements

“ Employee Training. (See also Part 4.2.8)”

“Train personnel at least once a year and address the following activities, as applicable: used oil and spent solvent management: fueling procedures: general good housekeeping practices: proper painting procedures: and used battery management.”

23INCOG

Water Transportation12.Q.4.6

“ Employee Training. (See also Part 4.2.8)”

“As part of your employee training program, address, at a minimum, the following activities (as applicable): used oil management; spent solvent management; disposal of spent abrasives; disposal of vessel wastewaters; spill prevention and control; fueling procedures; general good housekeeping practices; painting and blasting procedures; and used battery management.”

24INCOG

Ship and Boat Building or Repair Yards12.R.4.6

“ Employee Training. (See also Part 4.2.8)”

“As part of your employee training program, address, at a minimum, the following activities (as applicable): used oil management; spent solvent management; disposal of spent abrasives; disposal of vessel wastewaters; spill prevention and control; fueling procedures; general good housekeeping practices; painting and blasting procedures; and used battery management.”

25INCOG

Treatment Works12.T.4.5

“ Employee Training. (See also Part 4.2.8)”

“At a minimum, one must address the following areas when applicable to a facility: petroleum product management; process chemical management; spill prevention and controls; fueling procedures; general good housekeeping practices; proper procedures for using fertilizer, herbicides and pesticides.”

26INCOG

Food and Kindred Products12.U.4.4

“ Employee Training. (See also Part 4.2.8)”

“Address pest control in your employee training program.”

Sector “U” includes processors of meat, dairy, fruits, vegetables, grains, bakeries, sugar, fats and oils, beverages, tobacco and other misc. food preparations.

27INCOG

Textile Mills, Apparel and Other Fabric Products12.V.4.4

“ Employee Training. (See also Part 4.2.8)”

“As part of your employee training program, address, at a minimum, the following activities (as applicable): use of reused and recycling waters; solvents management; proper disposal of dyes; proper disposal of petroleum products and spent lubricants; spill prevention and control; fueling procedures; and general good housekeeping practices.”

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Printing and Publishing12.X.3.E

“ Employee Training. (See also Part 4.2.8)”

“As part of your employee training program, address, at a minimum, the following activities (as applicable): spent solvent management; spill prevention and control; used oil management; fueling procedures; and general good housekeeping practices.”

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Rubber, Miscellaneous Plastic Products and Miscellaneous Manufacturing Industries

12.Y.2.B

“B. Zinc Bags. Ensure proper handling and storage of zinc bags at your facility. Following are some BMP options: employee training on the handling and storage of zinc bags, indoor storage of zinc bags, cleanup zinc spills without washing the zinc into the storm drain, and the use of 2,500-pound sacks of zinc rather than 50- to 100-pound sacks;”

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Questions?