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I am attaching the hand-out that we go over during the training showing all of the items that are discussed within the <br /> above topics. If this still does not meet the training requirements, please let me know and we will need to address this <br /> at our next training of staff under the SPCC Plan. <br /> Thank you, <br /> Jill Davis, CSRM <br /> Risk Management-Workers' Compensation Claims Analyst Lodi Unified School District <br /> 1305 East Vine Street <br /> Lodi, CA 95240 <br /> (209) 331-7145 (Direct) <br /> (209) 269-0133 (Cellular) <br /> (209) 331-7142 (Fax) <br /> jidavis@lodiusd.net<ma ilto:jidavis@lodiusd.net> <br /> From: Baker, Lydia [mailto:lbaker@sjgov.org] <br /> Sent:Thursday, April 16, 2020 9:22 AM <br /> To:Jill Davis (Risk Management)<jidavis@lodiusd.net<mailto:jidavis@lodiusd.net>>; Annette Galindo (Transportation) <br /> <agalindo@lodiusd.net<mailto:agalindo@lodiusd.net>>; Ed Bonham (Transportation) <br /> <ebonham@lodiusd.net<mailto:ebonham@lodiusd.net>> <br /> Subject: RE: Return to Compliance <br /> CAUTION:This email originated from outside LodiUSD. Do not click any links or open attachments and verify the sender <br /> if this is unsolicited email. <br /> Hello Jill, <br /> If the necessary training on the SPCC plan was done in December then I just need to see something that shows it was <br /> done. The training sign in sheets you are provided are titled, "HMMP & No Idle Law," "Oil Spill & Hazmat Clean-up, " <br /> "Personal Protective Equipment Training," "HazWaste Generator/CERS Basics," and "Hazardous Waste Management". <br /> Perhaps you can provide the contents of the trainings to show that the SPCC plan training was provided because the <br /> titles of the trainings don't appear to cover the entire SPCC plan. Here are what the regulations require for SPCC plan <br /> training: <br /> 40 CFR 112.7(f): Personnel,training, and discharge prevention procedures. (1)At a minimum,train your oil-handling <br /> personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; <br /> applicable pollution control laws, rules, and regulations; general facility operations; and,the contents of the facility SPCC <br /> Plan. <br /> (2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility <br /> management. <br /> (3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure <br /> adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges <br /> as described in § 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures. <br /> If the December training does not cover the above minimum requirements then staff need to be trained on the above. <br /> The training must be done within the following timelines. <br /> 40CFR 112.5(a): Amend the SPCC Plan for your facility in accordance with the general requirements in § 112.7, and with <br /> any specific section of this part applicable to your facility,when there is a change in the facility design, construction, <br /> operation, or maintenance that materially affects its potential for a discharge as described in § 112.1(b). Examples of <br /> changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning <br /> containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of <br /> piping systems; construction or demolition that might alter secondary containment structures; changes of product or <br /> 4 <br />