OKR05 Employee Training
Requirements
OKR05 Stormwater Industrial Permit Workshop
28th Resource Management Conference
Tulsa Garden Center
March 26, 2015
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
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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.
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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?
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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.
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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, antifreeze, mercury switches and solvents.”
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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 nonindustrial 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.”
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Water Transportation
12.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.”
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Ship and Boat Building or Repair Yards
12.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.”
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Treatment Works
12.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.”
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Food and Kindred Products
12.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.
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Textile Mills, Apparel and Other Fabric Products
12.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 Publishing
12.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 100pound sacks;”
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Questions?
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