Oil Spill Training

Oil spill training is an important element in EPA's oil spill prevention and preparedness efforts. Studies indicate that a significant number of oil spills at fixed facilities are caused by operator error, such as failing to close valves or overfilling tanks during transfer operations. Because operator error is more likely to be a factor in causing spills, training and briefings are critical for the safe and proper functioning of a facility.

Training provides a number of benefits in the area of oil spill preparedness. Proper training of facility personnel can reduce the occurrence of operator-related spills and 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 SPCC Plan. EPA offers training courses for conducting proper response measures in cases of inland oil spills as well as a drill/exercise program for oil-storage facilities.

EPA Training Requirements

EPA requires owners and operators of facilities subject to the Oil Pollution Prevention regulations to conduct training on facility-specific oil spill prevention and response measures. Under the Oil Pollution Prevention regulation, EPA requires owner/operators to instruct their personnel on the operation and maintenance of equipment to prevent discharges of oil. In addition, regulated facilities should have a designated person who is accountable for oil spill prevention and who reports to line management. The current regulations also compel facility owners or operators to conduct spill prevention briefings for their operating personnel as often as needed to ensure an adequate understanding of the SPCC Plan for that facility.

In 1994, EPA added requirements for oil spill response training for facilities that are required to prepare a facility response plan. Specifically, facility owner or operators are required to develop and implement a facility response training program if their facility is determined to pose substantial harm to the environment. According to the rule, training must be specific in nature and scope to the responsibilities of facility personnel identified in the facility response plan. In addition, facilities are required to develop and implement an oil spill drill/exercise program. The drill/exercise program is comprised of tabletop and deployment exercises that are both announced and unannounced, as well as participation in larger area drills and exercises. To satisfy the drill/exercise program, facilities may participate in the federal government's Preparedness for Response Exercise Program.

In 1991, EPA proposed revisions to the SPCC regulations to clarify the mandatory nature of the oil spill prevention training requirements and proposed several additional requirements. Specifically, EPA proposed the following spill prevention training requirements:

• All employees who are involved in oil-handling activities would be required to receive 8 hours of facility-specific training within one year of the final regulations.
• In subsequent years, employees would be required to undergo 4 hours of refresher training.
• Employees hired after the training program has been initiated would be required to receive 8 hours of facility-specific training within one week of starting work and 4 hours each subsequent year.

EPA currently is reviewing and evaluating comments received from the public on these proposed revisions.