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5WHO MUST BE TRAINED?9… at a minimum, all “oil-handling personnel”.9‘‘Oil-handling personnel’’ is to be interpreted according to industry standards, but includes employees engaged in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. 9The EPA does not interpret the term to include secretaries, clerks, and other personnel who are never involved in operation or maintenance activities related to oil storage or equipment, oil transfer operations, emergency response, countermeasure functions, or similar activities. O-I includes storeroom personnel9… conduct discharge prevention briefings for oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility40 CFR 112.7(f)