Training Is Not an Option, It Is a Requirement
Why is one of the most critical components of your storm water program the one most likely to be forgotten about? I am talking about training that often is neglected, but is a key indicator of success. Is it human nature to put off the things we don’t know about to go from A to B easily? Almost everything in industrial storm water permits is spelled out pretty clearly. The number of samples or inspections per year is a line item. The dates reports are due are easily found. The best management practices (BMPs) and outfalls to be inspected can wind up in an inspection checklist without too much effort. Heck, many states provide the inspection checklist or storm water pollution prevention plan (SWPPP) template. But this training is usually “ensure that all team members implementing the various compliance activities of this general permit are properly trained to implement the requirements of this general permit, including, but not limited to: BMP implementation, BMP effectiveness evaluations, visual observations and monitoring activities.” Seems a little vague to me, and if there is not even a timeframe in the permit, who cares?
Well, the problem with not caring about training is that having a component storm water team and facility staff that have a general awareness about storm water is likely going to make or break your storm water program. When industrial facilities get into trouble for their storm water permits, it is usually because they missed a deadline or report, or storm water samples were over benchmarks, limits and/or levels. Missing deadlines or reports can be avoided with a good reminder system and an understanding of the risks and ramifications of industrial storm water permits. Too often we see facilities put storm water reporting responsibilities on any random person they find under their roofs. This doesn’t work if the person responsible doesn’t realize that the deadlines are real, understand the fines and lawsuits cost big dollars, or know how to complete a report (e.g., an annual evaluation) that passes the test.
It gets even worse when you talk about storm water sampling, because all too often a company will tell a facility manager who has no storm water training to “take a sample and send the report to the state.” An untrained staff member grabs a storm water sample, scrapes the bottle along the bottom of the ditch, erroneously has a boatload of sediment in the sample, and then submits that lab report to the state with total suspended solids (TSS) at 1,800 mg/L, well above the numeric action level (NAL) of 400 mg/L. True story. This happened to at least four facilities I talked to last year. Swap TSS for pH and the number of facilities goes up another 6 to 10. The problems here are that 1) the facility manager does not know how to properly collect a sample, which means bad results, and 2) they don’t know the ramifications of bad results, so they and their boss never review the results to fix problems ahead of time.
How do you fix this problem? Training is the solution, but it has to be done well. The keys to a good training program for industrial storm water revolve around a few things we have learned running more than 25 training sessions a year for companies, covering hundreds of facility staff, managers, contractors, etc. First, the training has to be regular. That means at least once a year, your storm water team should be refreshing their storm water education. Topics should include the permit requirements, risks of non-compliance, how to perform inspections, what are the potential pollutants, which BMPs are critical and how to properly collect a sample. Ideally, the storm water team is supplementing that with quarterly “tailgate”-style sessions (15 minutes in the field) on a hot topic, such as plastic pellet cleanup procedures or dumpster lids staying down. The annual training should not be limited to just the storm water team—we like to include general storm water awareness training for all facility staff in our annual sessions. Topics such as risks of non-compliance (big fines/lawsuits gets people’s attention), potential pollutants and BMPs are the three main talking points. These sessions should be no more than 30 minutes, or else you get staff catching up on their Zs.
For both of these sessions—storm water team and general awareness—making it relatable and engaging is key. Ask questions about how staff members use water today. Do they swim, fish, sail, drink water, etc.? Start your training sessions by asking questions, not just reading PowerPoints. Get a dialogue going.
The third key component of training is to take staff members outside. Get out of the chairs and onto the yard. Storm water permits cover everything exposed to the rain, so it doesn’t make sense to only be indoors when you are teaching about potential pollutants and BMPs. As part of your training sessions, you should walk the site and talk through pollutants, problems and solutions. Take the learning in the classroom and apply it to the actual site. Make the site walk engaging by asking questions, including, “What are the potential pollutants here?” “Are these BMPs working?” and, “What can we do to keep pollutants out of storm water?”
Start by actually conducting training, because too often it has not been done in facilities for years, or ever. Companies can jump on the recent trend to move training to an online environment, which is great, because it means less downtime on the production facility (the money-making side of the business). However, whether the training is online or in a classroom, staff should not simply be listening to someone read slides. It should be engaging, thoroughly explain the whys and be interactive. Get outside the classroom and dig into potential pollutants, BMPs and how to collect a storm water sample that will not unnecessarily result in exceedances. If done well, training can be your storm water program’s best asset and set your company up for a successful storm water year. Training is no longer optional—it is a core permit requirement, and likely the cheapest way to avoid million-dollar lawsuits and fines.
