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5 <br />WHO MUST BE TRAINED? <br />✓… at a minimum, all “oil-handling personnel”. <br />✓‘‘Oil-handling personnel’’ is to be interpreted according to industry standards, but includes <br />employees engaged in the operation and maintenance of oil storage containers or the operation <br />of equipment related to storage containers and emergency response personnel. <br />✓The EPA does not interpret the term to include secretaries, clerks, and other personnel who <br />are never involved in operation or maintenance activities related to oil storage or equipment, <br />oil transfer operations, emergency response, countermeasure functions, or similar activities. <br />O-I includes storeroom personnel <br />✓… conduct discharge prevention briefings for oil-handling personnel at least once a year to <br />assure adequate understanding of the SPCC Plan for that facility <br />40 CFR 112.7(f)