UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INGTON.
JUL I 5
*
«ot*.c WASHINGTON. O C 20460
THE AO'MISlSTPATQR
MEMORANDUM
SUBJECT: Agency-Wide Program to Train, Develop and Recognize
Compliance Inspectors/Field Investigators
TO: Assistant Administrators
Inspector General
General Counsel
Associate Administrators
Regional Administrators
Compliance Program Directors
Environmental Services Division Directors
Achieving and maintaining a high level of compliance with
environmental laws and regulations is one of our most important
goals. Personnel conducting compliance inspections and field
investigations play a key role in the success of the national
enforcement programs. EPA Order 3500.1, signed by Jim Barnes
on June 29, 1988, and the accompanying program description
will now establish a comprehensive program to train, develop
and.recognize the contribution of EPA's compliance inspectors
and field investigators, and others who perform this function
under EPA's statutes.
State and local personnel conduct the majority of environ-
mental compliance inspections and investigations under delegated
or approved programs. EPA will work with the State and local
agencies to encourage State, and local training programs and
to identify and meet training needs for their compliance
inspectors/field investigators. These agencies are welcome
to use all relevant training materials and participate wherever
possible in the training opportunities EPA offers.
Although no training program or periodic recognition
for achievement can guarantee performance or substitute for
effective day-to-day work, I believe that these actions will
help to foster professionalism and quality in inspections and
investigations, commensurate with the importance of this
function to our mission.
vtachments
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AGENCY-WIDE PROGRAM TO
TRAIN, DEVELOP AND RECOGNIZE
COMPLIANCE INSPECTORS/FIELD INVESTIGATORS:
A PROGRAM DESCRIPTION
June 1988
U.S. Environmental Protection Agency
Washington, D.C. 20460
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300B88O2O
ACKNOWLEDGEMENTS
This Program Description vas prepared for the Agency-wide Work
Group on Inspector Training and Development by the Compliance
Policy and. Planning Branch, Office of Compliance Analysis and
Program Operations, Office of Enforcement and Compliance
Monitoring (OECM). The overall project manager and principal
author vas Rebecca A. Barclay. Appendices D-l to D-9, Summaries
of Program-Specific Curricula, were prepared by the Program
Offices.
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DISCLAIMER STATEMENT
No language in EPA Order 3500.1 and/or this policy shall
create any right in any person to use this Order as a basis for
suit, or as a basis for defense, against EPA; it is intended as
notice solely for internal personnel administration and its terns
shall not inure to the benefit of any person who is not employed
by EPA. Nothing in EPA Order 3500.1 nor this policy shall affect
adversely admissibility of evidence offered by the United States
in any proceeding, or the competency of witnesses called by the
United States. .
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EXECUTIVE SUMMARY
EPA's program to train, develop and recognize compliance
inspectors and field investigators does the following:
o Focuses on Quality Inspections, not just "training for
training's sake,'* by continuing to rely on the Performance
Management System and the first-line supervisor's judgment in
evaluating the field performance and the readiness of an
inspector to lead an inspection. Development of criteria for
quality inspection reports and Supervisors' Guides for assessing
training needs and requesting exceptions are new tools provided
for this purpose.
o Establishes Minimum Training Requirements Before Leading
Inspections, in the form of a Basic Inspector Curriculum
developed by OECM, and Program-Specific Minimum Curricula
developed by the Program Offices, with Regions' and States'
participation.
o Addresses a Broad Audience including EPA's new and experienced
inspec-ors and first-line supervisors, along with EPA's
contractors leading compliance inspections and field
investigations for compliance and enforcement-related purposes.
o Maintains Flexibility in Implementation by phasing in
requirements for new inspectors and all first-line supervisors on
October 1, 1989, and for experienced inspectors on October 1,
1991. The Program also allows exceptions to requirements based
on previous training and experience in most instances; however,
new inspectors cannot be excepted from the Basic Curriculum.
o Assists State/Local Personnel, by encouraging States to adopt
structured training programs for inspectors, sharing EPA
developed training materials, assessing training needs during the
State/EPA Enforcement Agreements Process,.and offering to train
State instructors.
o Ensures Ongoing. Consistent Delivery of Training, by using
the EPA Institute model for the Basic Curriculum, continuing
contractor or grant support in program-specific situations, and
relying on a combination of these approaches to deliver
health and safety training required by existing EPA Orders.
o Maintains Program Accountability, by assigning responsibilities
for development, delivery, tracking and evaluation of training in
Headquarters and the Regions, establishing standing work groups
and incorporating evaluation throughout the program design.
o Builds Recognition into the Work by encouraging more feedback
and .acknowledgment of the inspector's contribution to enforcement
actions and by encouraging AAs and RAs to reward excellence in
compliance monitoring inspections/field investigations.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY pp. i
I. INTRODUCTION 1-2
I. DEVELOPING AND EVALUATING QUALITY IN
COMPLIANCE INSPECTIONS AND FIELD INVESTIGATIONS 2-4
A. Performance Evaluation
B. Assessing Training Needs
C. Standing Work Groups
I. TRAINING AND DEVELOPMENT 4-16
A. Curriculum
B. Applicability
C. Requirements and Exceptions
D. Implementation of Training
E. Implementation Timetable
F. Delivery of Training to State/Local
Personnel
V. RECOGNIZING EXCELLENCE 16-17
A. Building Recognition into the Work
B. Supporting Professional Development
and Recognition
C. Enhancing Public Recognition
APPENDICES
A. DEFINITIONS
B. SUMMARY OF HEALTH AND SAFETY REQUIREMENTS
C SUMMARY OF BASIC INSPECTOR CURRICULUM
D. SUMMARIES OF PROGRAM-SPECIFIC CURRICULA
E. SUMMARY OF RECOMMENDED MULTI-MEDIA
(MULTI-PROGRAM) TRAINING.
F. SUPPLEMENTAL TRAINING
G. ACCOUNTABILITY
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AGENCY-WIDE PROGRAM TO TRAIN, DEVELOP, AND RECOGNIZE
COMPLIANCE INSPECTORS/FIELD INVESTIGATORS
I. INTRODUCTION
In June, 1988, the Administrator issued a policy,
entitled, "Agency-wide Program to Train, Develop and
Recognize Compliance Inspectors and Field Investigators."
The primary goal of this program is to foster quality compliance
inspections and field investigations as critical components
of" the Environmental Protection Agency's (EPA's) compliance
monitoring and enforcement functions.* It is the continuing
responsibility of the compliance inspector, or field invest-
igator, and his/her first-line supervisor to focus on
quality, not just quantity and timeliness in meeting the
commitments for inspections and investigations. Managers
and staff at all levels should support this emphasis throughout
the Regions and Headquarters.
There are existing systems and responsibilities which
EPA will continue to rely upon to ensure quality. Among
these are development and provision of inspection guidance
manuals, policies, and procedures; management systems
including performance standards and performance appraisals;
and decisions by the first-line supervisor on assignments
and the readiness of personnel to represent the Agency
in the field with the regulated commmunity. This document
explains several new actions designed to reinforce the goal
of quality in EPA's compliance monitoring programs and
details the responsibilites of Agency managers and staff in
carrying out these actions.
Highlights of these actions include:
o Using New Tools to Assess Inspectors/Investigators'
Training needs;
*••
o Reinforcing Quality in Inspection Reports;
o Establishing Formal Training Curricula and
Requirements;
* Activities encompassed in the tern compliance inspections/
field investigations are shown in "Definitions," Appendix A.
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o Creating Standing Work Groups to Improve EPA's
Compliance Inspection Programs? and
o Building Recognition into the Dav-to-Dav Work.
Taken together these key actions should help create
the necessary conditions for high quality inspections,
thereby strengthening the Agency's compliance and enforcement
programs. The remainder of this document describes these
and related actions in more detail.
II. DEVELOPING AND EVALUATING QUALITY IN INSPECTIONS AND
INVESTIGATIONS
A first-line supervisor has very important responsi-
bilities regarding employee development. The supervisor
makes decisions on the individual's training needs, the
best ways to meet those needs, if and when an individual
is ready to lead an inspection, the annual performance
rating, and when promotions are warranted. These activities
are done cyclically and are very closely interrelated. To
assist supervisors with these responsibilities, the following
will occur.
A. Performance Evaluation
Training prerequisites alone do not ensure high quality
performance in the field. Nor is completion of these the
sole basis for a first-line supervisor to decide that an
employee is ready to lead inspections. Personal qualities
such as individual motivation and judgment are among the
factors a supervisor considers. EPA's Performance Management
Systems provides the framework for assessing the individuals
readiness for leading inspections/investigations and the
quality of performance.
When evaluating the quality of performance of compliance
inspectors/field investigators, first-line supervisors are
strongly encouraged to use three primary methods with related
performance standards:
o Review of inspection plans, files and reports against
established criteria for quality; Criteria for evaluating the
quality of inspection reports should be developed in conjunction
with case development personnel and a system of periodic reviews
should be established that offers clear and prompt feedback.
Some programs and Regions already use this approach.
o Direct observation of the inspector's performance in t.-.e
field; Because inspectors operate independently in the field, it
is crucial for the supervisor to have direct knowledge of how t^
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individual is performing in the field as EPA's representative.
Periodically observing and evaluating the inspector in the field
can be a useful way of developing such knowledge.
o Self-evaluation; Self-evaluation is always an important
component, so that the supervisor knows whether the inspector
understands what is important about quality in performance -
and how the individual perceives his/her own accomplishments.
B. Assessing Training Needs
As part of this program, Program Offices and OECM
are developing Supervisors' Guides to help supervisors assess
previous training and experience against the established
curricula. These guides will link the training curricula to the
knowledge, skills and abilities (KSAs) that are related to the
job. They offer a common framework for applying training
requirements, annually reviewing training needs, preparing
Individual Development Plans, and requesting exceptions from,
training requirements. These guides will be available during ^Y
1989.
Also Program Offices and OECM are encouraged to develop
and test objective measures to assess what individuals have
learned through the training program and to use this i. formation
in deciding future training needs. Such measures of progress
could be self assessments built into training mater*' *ls, mock
inspections or other means of evaluating learning.
C. Standing Work Groups
"3*
Standing work groups are important to support and promote
quality^in all aspects of EPA's compliance inspection/monitoring
programs. These groups provide opportunities for discussion
among peers and can enhance the sense of professionalism among
the Agency's very diverse group of compliance inspectors and
investigators.
Program Offices will establish standing work groups composed
of Headquarters, Regional and State compliance inspectors/
investigators and other compliance program staff to exchange
ideas about work methods and strategies; to assist in design,
development and review of training materials; and to develop
better mechanisms for timely dissemination of information on
policy and regulatory changes related to inspections/
investigations. Program Offices have already used such groups
effectively in the development of the program-specific curricula
that form a central component of the training program described
below. . .
Related to this, the Program Offices should also establish
mechanisms to keep inspectors/investigators abreast of
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policy, regulatory, and procedural changes between training
cycles (i.e. newsletter, procedures memoranda, inspection manual
inserts),
Also, OECM will establish'a board of Senior Agency Managers,
inspectors and investigators from Headquarters and Regions to
advise OECM in updating EPA Order 3500.1, overseeing and
implementing this program, updating the Basic Curriculum, and
developing other projects to improve the Agency's compliance
monitoring programs.
III. TRAINING AND DEVELOPMENT
The primary goal of the EPA's national training program is
to develop and maintain among EPA employees, the knowledge,
'skills and abilities needed for high quality compliance
inspections on a consistent and continuing basis. EPA Order
3500.1'establishes formal curricula and minimum requirements
for all EPA inspectors, first-line supervisors of inspectors,
EPA contractors and others conducting inspections under EPA's
statutes. The Order also establishes procedures for exceptions
to the training requirements.
This is the first time the Agency has articulated a
national, comprehensive approach to professional development
of compliance inspectors. Program Offices and the Office
of Enforcement and Compliance Monitoring (OECM) are responsible
for developing and maintaining these training programs on a
continuing basis. Both the Regional Offices and Headquarters
Program Offices have important roles in delivering the training.
A. Training Curricula
The curricula consist of three required elements:
Occupational Health and Safety, Basic, and Program-Specific
Minimum Curricula. Appendices B, C, and D respectively describe
each curriculum. Recommendations on multi-media (multi-program)
training appear in Appendix E. Supplemental training to
strengthen skills such as negotiations and appearing as an expert
witness are also available, as described in Appendix F. For more
information about each curriculum, contact the representative
listed in each summary. Briefly these curricula are:
1. Occupational Health and Safety; EPA Orders 1440.2 and
1440.3 establish requirements for knowledge of hazard
recognition, personal protective equipment, and general health
and safety practices. The Occupational Health and Safety Staff
(Office of Administration and Resources Management) is
responsible for updating these Orders and the associated
curricula. (See App.endix B.) Training required by these Orders
is an essential component of the Basic Curriculum for inspectors.
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2. Basic inspector Curriculum; This Curriculum establishes
required t. ining to provide a comprehensive overview of
Jcnowledge and skills needed for compliance inspections/field
investigations under any EPA statute. It consists of a course,
that integrates legal, technical and administrative subjects,
with communication skills. The goal of this training is to
foster a common understanding of the role of the compliance
inspector and EPA's general enforcement philosophy; the
enforcement authorities and enforcement process under all the
major environmental statutes; and to develop skills needed to
c/ather information, collect evidence, and write objective reports
of findings. OECM is responsible for developing and updating
this course and overseeing implementation of the curriculum.
Appendix C describes the curriculum in more detail. The
curriculum also encompasses the training required by.the Health
and Safety Orders cited above.
3. Program-Specific Curricula; Each Program Office has
defined a minimum curriculum of legal, programmatic, and
technical subjects to prepare an inspector to lead specific types
Of inspections, recognize violations, and to properly obtain
information/evidence. The curriculum must be completed prior to
leading a inspection. Appendix D contains a brief summary of
each Program Office's minimum curriculum. If an individual is
leading inspections in more than one program area, s/he must
complete the minimum curriculum for each program area before
leading an inspection in that program.
s>»
Each Program Office has or will develop advanced or
specialized curricula for particularly complex or difficult types
of inspections, and will incorporate these into their training
plans*as they are developed and approved by training work groups.
The proper mix of inspectors with specialized training is the
decision of Regional management, depending on needs for
specialized types of inspections and knowledge of control
technologies or industries.1 Any inspector seeking such
specialized training should have previously completed the Basic
and Program-Specific Minimum Curricula.
4. Multi-Media fMulti-Programl Training
The goal of multi-media (multi-program) training is
to develop a flexible work force capable of responding to
changing program priorities and to enable more efficient
use of travel time and money. Regions are encouraged to support
^•Throughout this document, wherever Regional Administrator
or Regional"Management appears, the same authories or
responsibilities apply to any Assistant Administrator with
Headquarters-based compliance inspectors/field investigators,
for example, in the Air Mobile Sources Program.
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multi-media (multi-program) training where the relationship
between the requirements of two or more programs or the location
of the facilities makes it cost-effective to do so. Appendix £
recommends areas for future development of multi-media (multi-
program), inspections and associated training.
v
5. Supplemental Training
To supplement the required Basic Curriculum, EPA
inspection personnel are encouraged to take other training
courses designed to strengthen specific skills associated with
the compliance and enforcement process, such as administrative
hearings/trials, negotiations skills, appearing as an expert
witness, and criminal enforcement techniques. See Appendix F
for additional information and whom to contact.
6. Refresher-Training
: The purpose of refresher training for inspectors and their
first-line supervisors is to reinforce basic knowledge and
skills and to keep current the specific technical, legal
and programmatic knowledge and skill needed for high quality
inspections/investigations. Refresher training in occupational
health and safety is required annually under EPA Orders 1440.2
and 1440.3.
Refresher training in both the Basic and Program-Specific
Minimum Curricula is strongly recommended every three years at a
minimum. The first-line supervisor will determine the frequency
of such training based on the needs of the individual, and
changing emphases or needs in the Compliance Program. This means
that training is ongoing, rather than a one-time occurrence.
Program Offices may specify refresher training more frequently
for some or all parts of their curricula.
B. Applicability
This section elaborates on EPA-Order 3500.1, Section 2 so
that staff and managers implementing this training program for
compliance inspectors/field investigators have a broader
understanding of its applicability to EPA personnel, contractors
and others performing inspections under EPA's statutes, and to
State and local personnel.
1. EPA Compliance Inspector/Field Investigators, and First -
Line Supervisors.
The requirements of this program apply to all EPA compliance
inspectors/field investigators and the first-line supervisors of
individuals who lead or oversee compliance inspections/field
investigatons. While program requirements apply to both "new"
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and "experienced" personnel as defined in the Order, there are
some distinctions in training requirements and exceptions to
them. Regional Administrators and those Assistant Administrators
with inspectors based in Headquarters and are responsible for
determining which personnel fall in the categories of "new" and
"experienced," and which requireme-.tr and/or exceptions apply.
Although not required, anyone partir.pating or assisting in
compliance inspections/field investigations is strongly
encouraged to complete the Basic and Program-Specific Curricula.
Not all individuals performing work as On Scene Coordinators
(OSCS) and Remedial Project Managers (RPMS) under the CERCLA
program are covered by the definition of the compliance
inspection/field investigation function. OSWER will develop
additional program guidance to assist Regions in distinguishing
these functions from other programmatic responsibilities.
2. EPA Contract Personnel and Others
In order to be effective representatives of EPA and carry
out Agency policies and procedures, EPA contract personnel,
consultants, and other personnel performing compliance
inspections/field investigations under EPA's statutes must
fulfill the requirements of the Basic and Program-Specific
Minimus Curricula prior to leading any inspections. Program
Offices and Regions are responsible for assuring that under
future contracts and assistance agreements awarded under the
Senior^Environmental Employment Program involving >r.pliance
inspections, training is required by means of sta. ments of work
and/otk other appropriate vehicles.
• *& '
3. State/Local Personnel
Because State and local personnel perform more than 80%
of all environmental compliance inspections nationally under
delegated or approved programs, it is essential for EPA to
work with the State and local agencies to help assure that
their personnel too receive ample training and development.
Although this program does not require State/local agencies to
train compliance inspectors/field investigators, it does
encourage these agencies to adopt structured approaches to
train their personnel, recognizing State-specific concerns and
the value of alternate instructional methods, and to use EPA-
developed training materials where appropriate.
EPA recognizes that States' training needs differ from
EPA's needs in areas such as program requirements and
regulations, but there are common areas of need, for example in
technical field methods and investigative techniques. In many
instances, States are the repository of expertise that EPA needs
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B
to tap as well. EPA's training program recognizes the importance
of this mutual relationship in design and implementation of
inspector training (See discussion in Section III. F).
C. Requirements and Exceptions
The Basic and Program-Specific Minimum Curricula establish a
core set of subjects and field experience that must be completed
by each inspector. Regions are encouraged to tailor training
materials to suit local needs, while still being consistent
.with the national program. This means that Regions may add
to the course content but coverage of the essential content
is required. Completion of any of the training required
under this program means completing self-study, OJT and/or
participation in classes covering the content of the curriculum.
Training requirements are oriented around key stages
in the process of employee development as follows:
1. Prerequisites to Field Activities
EPA Order 1440.2 established basic health and safety
training requirements that apply to all of EPA's compliance
inspectors/field investigators and their first line supervisors,
and that are prerequisites to any activities in the field.
The training requirements of EPA Order 1440.3 may also apply.
2. Prerequisites to Leading Inspections
EPA Order 3500.1 establishes minimum training requirements
under the Basic and Program-Specific Minimum Curricula for
all of EPA's compliance inspectors/field investigators that
constitute prerequisites to leading or overseeing inspections/
investigations performed by States/local personnel, EPA
contractors or others conducting inspections under EPA's
statutes.
3. Within One Year When Supervising
EPA Order 3500.1 establishes minimum training requirements
under the Basic and Program-Specific Minimum Curricula for
all first-line supervisors of personnel who lead or oversee
compliance inspections that should be completed within one
year of appointment to the supervisory position. If the first-
line supervisor directs inspectors/investigators in two or more
programs, the supervisor may need additional time to complete all
of the applicable Program-Specific Minimum Curricula, and should
do so as soon as practicable.
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4. Procedure for Exceptions
Paragraph 9 (d), EPA Order 1440.2 and EPA Order 1440.3
provide procedures that should be followed to seek exceptions
to health and safety training requirements. Paragraph 8 (c),
EPA Order 3500.1 establishes the procedure for obtaining
exceptions to requirements to complete the Basic and Program-
Specific Minimum Curricula. In the Regions, the responsibility
•for approving exceptions rests with the Regional Administrator.
Delegation below this level may be made to the Deputy Regional
Administrator or a panel of managers, excluding the immediate
first or second-line supervisors of the individual for whom
an exception is being requested.
For those Program Offices with inspectors based in
Headquarters, the authority to approve requests for
exceptions for these individuals rests with the Assistant
Administrator. Delegation below this level may be made
to the Deputy Assistant Administrator, the Office Director, or in
the case of OECM, to the Director of NEIC. In no case does the
AA approve requests for exceptions made for personnel based in
the Regions.
V5. Exceptions to Requirements for Completing Basic and
:* Program-Specific Minimum Curricula
.^Regional Administrators or Assistant Administrators, or
their delegatees, are responsible for determining whether each
inspector or first-line supervisor is "new" or "experienced"
as defined in EPA Order 3500.1.
The following chart: (FIGURE 1) shows what options exist for
new and experienced inspectors/investigators and first-line
supervisors of inspectors to receive exceptions to these
requirements. These exceptions must be based on an evaluation of
each inspector's or supervisor's previous training and experience
as compared to the required curricula. The Supervisors'
Guides discussed in Section IZ. B are the primary tool for
performing this assessment.
For the Basic Curriculum, the policy of no exceptions for
new personnel is important because this training is the common
foundation on which the Program-Specific Minimum Curricula
builds. Exceptions for some experienced employees may be
appropriate. Nonetheless, experienced inspectors are strongly
encouraged to take the Basic Curriculum even if excepted from it
because it is useful as refresher training and allows them to
share experiences with new inspectors.
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For Program-Specific Curricula, a limited number of
exceptions are possible for both new and experienced employees,
based on previous training and experience. Supervisor's Guides
will provide criteria for such exceptions.
FIGURE 1. SUMMARY OF POLICY ON EXCEPTIONS
TO TRAINING REQUIREMENTS
BASIC
CURRICULUM
NEW
INSPECTORS/
INVESTIGATORS
AND 1ST-LINE
SUPERVISORS
EXPERIENCED
INSPECTORS/
INVESTIGATORS
AND 1ST-LINE
SUPERVISORS
No
Exceptions
Possible
Limited Number
of Exceptions
Possible
PROGRAM-SPECIFIC
MINIMUM CURRICULUM
Limited Number
of Exceptions
Possible
Limited Number
of Exceptions
Possible
D. Implementation of the Training Program
In implementing the training program, the primary goal
is to develop and deliver, on a consistent and timely basis,
the necessary instructional materials and course offerings
required under the Basic and Program-Specific Minimum Curricula.
This section discusses key principles, responsibilities and
the timetable for developing and delivering this training
program to EPA personnel and assisting State/local personnel.
Appendix 6 contains a detailed list of functions and
responsibilities needed to make this program a success.
1. Design and Development of Training
Development of training involves the key functions of
defining the content, selecting the instruction method(s) and
developing the associated training materials. Design and
development of the Basic and Program-Specific Curricula and
the associated training materials are primarily functions
of Headquarters. The AA, Office of Administration and Resources
Management (OARM) is responsible for the Health and Safety
Curriculum, the AA, Office of Enforcement and Compliance
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Monitoring, for the Basic Curriculum, and the AA's, Program
Offices, for the Program-Specific Curricula. Key principles
for design and development are shown in Table 1. following.
Table 1. "
KEY PRINCIPLES FOR DESIGN AND DEVELOPMENT OF TRAINING
1. Active participation by the Regions/States in
annual assessment of training needs, and in
development and evaluation of training materials
and methods.
2. Instructional value of training materials and
methods is apparent; inspection manuals are not
sufficient.
3. Evaluation of training (including objective mea-
sures or tools for self-evaluation, pre-and
post-training) is built into the materials and
methods, and results are used by Program Offices
and OECM to develop or revise training.
4. Training methods and materials are selected and
designed to maximize their replicability and to
minimize delivery costs to a wide audience in-
cluding State and local personnel, EP7 contract-
ors and others.
2. Delivery of Training
This section describes the general aproach to delivery of
the Basic Curriculum and the Program-Specific Curricula to EPA
personnel. Delivery, means who receives what training, where and
how. Key principles appear in Table 2 following.
a. Balancing Flexibility with Effectiveness
Effective training depends on the instruction methods used
to convey the knowledge or techniques to be learned. OECM and
the Program Offices have identified the preferred method(s) of
instruction for their curricula, and have or will.develop
materials accordingly. When classroom instruction is the
preferred approach, a continuing concern has been the
availability of classes. To accommodate this concern, EPA Order
3500.1 and the Program Description do the following:
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(1) Broadly define classroom instruction to include
seminars, workshops, lecture-type or video-assisted classes,
or question-and-answer sessions following prior independent
self-study, i.e. any approach that fosters group interaction
with an instructor or an experienced inspector.
(2) For the Basic Curriculum, the preferred approach is
classroom instruction broadly defined as noted above, because
of the benefits to be derived such as team-building within
the Region and interaction between more experienced and less
'experienced inspectors. Reliance on in-house instructors to
implement this approach, under the EPA Institute, is the
preferred approach; however, contractor support may be
considered.
(3) Program-Specific Curricula, in deference to different
State approaches which rely more heavily on OJT, sometimes leave
the instructional method optional while expressing a preference
for classroom experience. Program Offices will work to
provide training materials in flexible formats to accommodate
these differences.
b. Regional responsibilities include;
(1) The Regional Administrator is responsible for planning
and organizing delivery of the Basic Curriculum in the
Region, relying on in-house instructors for any classroom
training. The Region should submit a written plan for this
to OECM by October 30, 1988. (See Appendix G for a more
detailed list of responsibilities.)
(2) For supervised self-study, the first-line supervisor
is responsible for ensuring that each inspector has the
necessary materials, and for on-the-job training, that
necessary field assignments under the supervision of an
experienced inspector are given.
(3) Regions must absorb the costs of course materials,
course attendance, travel for training of instructors or
attendance at courses in another Region, and in rare instances,
at Headquarters.
c. Headquarters responsibilities include:
(1) For the Basic Curriculum, OECM is responsible for
working with Regions, the EPA Institute (OARM) and Program
Offices with inspectors based in Headquarters, to assure
consistent and continuing delivery. OECM will maintain a list of
trained instructors from both Headquarters and other Regions vhc
will be available to supplement Region*"1 in. tructors. Each AA
with inspectors based in Headquart**-- ; -r- ^nsible for plannir.?
delivery of trie Basic Curriculum a '~ 1 ?ir.it a writter
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plan for thi~ to OECM by October 30, 1988 (may coordinate among
Program Offices or the Region.)
(2) For Program-Specific Curricula, the Program Offices are
responsible for assuring delivery occurs on a continuing
basis by a) assigning responsibilities for training delivery to
specific managers and staff, b) providing training contracts
for delivery and support, and/or c) providing grants to
university training centers or other nonprofit organizations to
deliver training, as appropriate.
Table 2.
KEY PRINCIPLES FOR DELIVERY OF TRAINING
1. To the greatest extent possible when using class-
room training, rely on in-house instructors for
delivery of the Basic Curriculum in the Regions
and Headquarters. When using on-the-job train-
ing, rely on in-house experienced inspectors
:.,- as trainers.
•.£."
,
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Figure 2. After these dates, neither new nor experienced
inspectors nay lead inspections unless they have completed
required training or have been excepted from the requirements.
Beginning October 1, 1989, first-line supervisors, must
complete training requirements within one year of appointment to
the supervisory position. Those supervisors who direct
inspectors/investigators in two or more programs may need
additional time to complete all of the applicable program-
specific minimum curricula and should do so a soon as
practicable.
EPA Order 3500.1 states that a "new" inspector is any
inspector hired or transferred subsequent to the issuance
date"of the Order. In the interim between the issuance date
(June 1988) and full implementation (October 1, 1989), these
employees are still subject to the requirements and exceptions
applicable to "new" inspectors. Even though they are gaining
experience, they do not convert to the "experienced" inspector
category; and they may not be excepted from the Basic Curriculum.
FIGURE 2. PHASING IMPLEMENTATION OF
TRAINING REQUIRED BEFORE LEADING AN INSPECTION
After this date After this date
New Inspectors Experienced Inspectors
Order cannot lead unless cannot lead unless
Issued training require- training requirements
ments are fulfille
Supervisor's (10/1/89)
Guides
Available
6/
88
Pilots*
Completed
1
W
88
1
12/
88
1
IO/
89
d. are fulfilled.
(10/1/91)
1
IO/ IO/
90 91
CALENDAR YEAR
*Pilots of the Basic Inspector Curriculum and Inspector Health 4
Safety Module.
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2. Availability of Training Materials
_ Not all the training .materials for Program-Specific
Minimum Curricula vill be available with sufficient time
before requirements must be met. This should not delay the
implementation of the training requirements. Each Program Office
vill identify what materials are available in the interim.
Program and Regional managers should use these existing
materials to cover the subject matter of the Program-Specific
Minimum Curricula.
When the preferred, new training materials or guides for OJT
become available under the Program-Specific Minimum Curricula,
compliance inspectors/field investigators shall have one
year thereafter to complete the training associated with
the material or be excepted, if eligible.
F. Delivery to State and Local Agency Personnel
State and local personnel are a substantial part of the
audience for inspector training, because they conduct the
vast majority of compliance inspections in support of
"ederal environmental statutes through delegation or author-
ization. Although EPA Order 3500.1 does not establish
requirements for any of these personnel, EPA will share training
materials (and training of State instructors where appropriate)
and encourages State and local agencies to adopt structured
approaches to train compliance inspectors/field investigators.
EPA encourages participation by State and local pet. >nnel in
available EPA course offerings, development and use of
better structured on-the-job training, and the use of
self-study materials with apparent instructional value.
To promote training of State and local agency personnel,
Regions, Program Offices vill:
o Encourage adoption of structured State/local
inspector training programs through information
sharing and participation in EPA's own curriculum
design, and promote cooperative State ventures
in cost-efficient training, such as that offered
under the Northeast Hazardous Waste Project.
o Assess States' training needs annually through the
State/EPA Enforcement Agreements process, and during
mid-year reviews identify priorities for training.
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16
o Establish the means to routinely communicate about
course offerings by Program Offices and their training
contractors to State and local personnel.
o offer to train State instructors in how to use training
materials developed by EPA, who can then train
other State/local employees on site.
o Identify individuals with expertise within EPA and within
State and local agencies to tap as trainers.
This approach allows State and local agencies wide
latitude to devise training programs appropriate to their
own circumstances while drawing on relevant training
materials available from Regions, Program Offices and OECM.
III. RECOGNITION FOR EXCELLENCE
Achieving better recognition of the crucial role that
EPA's compliance inspectors/field investigators play as the
front line of the enforcement programs is another important
aspect of the inspector training and development program.
Further steps to enhance recognition include building
recognition into the work, supporting professional develop-
ment and enhancing public recognition.
A. Building Recognition into the Work
Striving to increase recognition in the day-to-day
interactions between inspectors/investigators and enforcement
personnel and to better use EPA's existing awards system
are important as outlined below:
1. Routinely following through to recognize the inspector's
work in support of the enforcement response using letters
of commendation and appreciation where appropriate, at all
levels of Regional and Headquarters management.
2. Working with the EPA Institute to organize an annual
meeting or other forum to recognize the in-house instructors
for the Basic or Program-Specific Curricula.
3. Strongly encouraging AA or RA recognition of the
compliance monitoring function, using the existing merit and
honor awards system. OECM will work with the AAs or RAs to
issue joint awards for excellence in the compliance monitoring
function.
4. OECM, with its Advisory Committee, will identify
opportunities for using existing awards to recognize compliance
inspectors/field investigators for such p-:ti'-ities as:
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17
(a) Outstanding contribution to a major case by means
of high quality inspection/investigation, report
and overall technical support given to a case;
(b) Introducing new field techniques or methods; and
(c) Improved means of reporting compliance status.
B. Supporting Professional Development and Recognition
EPA endorses membership' by inspectors/investigators in
societies and associations which have objectives appropriate to
the inspector acquiring and maintaining knowledge, skills or
professional standing of .importance to the mission of the Agency.
Inspectors are encouraged to 1) assume leadership roles in job-
related professional societies and associations, 2) support
publications which deal with fields of knowledge important to the
Agency's mission, and 3) participate in professional society
meetings.2 Program Offices and Regions are encouraged to support
these activities with travel funds as appropriate.
C. Enhancing Public Recognition
Program Offices, Regional Administrators and OECM are
encouraged to publicize compliance monitoring and inspection
functions and excellent performance of those functions through
existing and new publications such as the EPA Management News
and the EPA Journal.
2Thomas, Lee M. Memorandum entitled, "Policy on Participation
in Professional Societies and Associations." USEPA.
November 26, 1986.
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APPENDICES A - G
June 1988
U.S. Environmental Protection Agency
Washington, O.C. 20460
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SUMMARY OP APPENDICES
A. DEFINITION
B. SUMMARY OF HEALTH AND SAFETY TRAINING ORDERS
C. SUMMARY OF BASIC INSPECTOR CURRICULUM
D. SUMMARIES OF PROGRAM-SPECIFIC CURRICULA
E. SUMMARY OF RECOMMENDED MULTI-MEDIA
(MULTI-PROGRAM) TRAINING
F. SUPPLEMENTAL TRAINING
G. ACCOUNTABILITY
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APPENDIX A
DEFINITIONS
The definitions in this appendix are quoted from
EPA Order 3500.1, "Training and Development for Compliance
Inspectors/Field Investigators,11 issued June 1988. The
numbering and lettering is identical to the Order.
5- DEFINITIONS.
a. Compliance Inspection/Field Investigation Function
The function includes leading, or overseeing State/local,
contractor or other personnel conducting, any of the following
activities for the purpose of establishing the compliance status
of facilities or sites with applicable-lavs, standards,
regulations and permits and/or of supporting appropriate
enforcement action (administrative, civil judicial or criminal),
including:
(1) planning and carrying out inspections of pollution
abatement equipment, relevant facility operations and maintenance
practices, self-monitoring practices and records, and laboratory
equipment;
(2) gathering and developing evidence, including but not
limited to emission monitoring measurements, other analytical
field procedures such as sampling and the associated quality
assurance procedures, and in depth engineering evaluations; and
(3) maintaining field logs, recording field observations
photographically, analyzing sampling and emissions data, and
preparing reports of observations along with any supporting
documentation.
Any EPA employee performing these activities regardless of
job title shall be considered a compliance inspector/field
investigator for the purposes of this Order. The terms
compliance inspector/field investigator will be used throughout
this Order. This function does not include field activities or
investigations for purposes such as research and development
which are unrelated to compliance monitoring or enforcement.
Not all individuals performing work as On-Scene Coordinators
(OSCs) and Remedial Project Managers (RPMs) under the CERCLA
program are covered by the definition of the compliance
inspection/field investigation function. Additional program
guidance will be developed to assist Regions in distinguishing
these functions from other programmatic responsibilities.
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b. Nev Compliance Inspector/Field Investigators. Including:
(1) Individuals newly employed by EPA subsequent to the
issuance date of this Order regardless of previous training in
and experience leading environmental compliance inspections/field
investigations, or
(2) Individuals rehired by EPA or transferred within
EPA, subsequent to the issuance date of this Order, with no
previous training in and experience leading environmental
compliance inspections/field investigations.
c. Experienced Compliance Inspectors/Field Investigators.
Including: Individuals.who were employed by EPA on the issuance
date of this policy, and/or who have previous training in and
experience leading environmental compliance inspections/field
investigations in any one of EPA's compliance and enforcement
programs.
d. First-line Supervisors of Inspectors. A first-line
supervisor is the immediate supervisor of the day to day work of
the inspector/investigator who leads or oversees compliance
inspections/ field investigations. The first line supervisor,who
is responsible for the official performance appraisal, may
be"new" or "experienced" as defined above in items 5(b) or 5(c).
-- «R- Contract Inspectors and Others. This category includes
contract personnel and employees of a grantee organization under
the Senior Environmental Employment Program performing compliance
inspections/field investigations under .EPA's statutes.
f. Leading an Inspection. Leading an inspection means
independently conducting a compliance inspection/field
investigation or directing an inspection/investigation with
others as support staff.
g. Curriculum. Curriculum refers to defined content
presented in a sequence of supervised self study, formal
on the job and/or classroom training:
(1) Supervised Self-Study. Self study means any
knowledge gained through independent, personal study, and
overseen by a first line supervisor or an experienced
inspector/investigator.
(2) On-the-Job Training. On the job training (OJT)
means structured training that relates principles or theories
to work related skills which are demonstrated and applied in
the field environment during an actual compliance inspection/
field investigation.
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(3) Classroom/classes. This refers broadly to any
form of instruction, flexible in format and size, to include
seminars, workshops, lecture-type or video-assisted classes,
or question and answer sessions following prior independent
self study, i.e., any approach that fosters group interaction
with an instructor or an experienced inspector.
h. Completing Required Training. Completion of required
training means completing self-study, OJT and participation in
classes covering the content described in applicable training
curricula.
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APPENDIX B
SUMMARY OF EPA ORDERS ON
HEALTH AND SAFETY TRAINING OF FIELD EMPLOYEES
A. SUMMARY OF EPA ORDERS 1440.2 AND 1440.3
EPA compliance inspectors and field investigators continue
to be subject to the training and other requirements of EPA
Order 1440.2 - Health and Safety for Employees Engaged in
Field Activities, and EPA Order 1440.3 - Respiratory Protection.
Pertinent portions of these Orders are summarized below.
For more complete information, refer to the Orders themselves
and/or contact the Occupational Health and Safety Designees
in the Reporting Unit (Headquarters or Regional Office) or
the Director, Occupational Health and Safety, Office of
Administration, U.S. Environmental Protection Agency, PM-273,
Washington, D.C. 20460 (FTS 8-382-3640).
1. EPA Order 1440.2 - Health and Safety for Employees in
Field Activities fJulv 12. 19811
a. Policy; Employees may not engage in routine field
activities until they have been trained and certified to a
level commensurate with the degree of anticipated hazards.
b. Training Requirements for Certification;
Basic 24 hours classroom training followed by !•' :ee days
level: of supervised field experience. Classroom subjects
include employees rights and responsibilities;
nature of anticipated hazards; emergency help and
self-rescue; vehicles - mandatory rules and
regulations; safe use of field equipment; use,
handling, storage, transportation of hazardous
materials; personal protective equipment/clothing, use
and care; safe sampling techniques.
Inter- 8 hours additional classroom training followed by three
mediate days of supervised field experience. Classroom subjects
level: include site surveillance and safety plan development;
use and decontamination of totally enclosed personal
protective clothing and equipment; use of field test
equipment for radioactivity, explpsivity.
Advanced 8 hours additional classroom training followed by three
level: days of supervised experience. Required for employees
who manage field activities at sites involving
hazardous materials. Classroom subjects include
management of restricted and safe zones; rules for
handling the press and viPs; and safe use of
specialized sampling equipment.
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Refre- At all levels, a minimum of 8 hours refresher classroom
eher instruction is required annually.
c. Exceptions to Training Requirementst The Director of
Occupational Health and Safety can certify an employee based
on an evaluation of previous training, education, and experience.
Recommendations for this type of certification are made by
the Occupational Health and Safety Designee at the employee's
Reporting Unit.
2. EPA Order 1440.3 - Respiratory Protection rJulv 24. 1981\
a. Policy; EPA shall provide certified respiratory protective
devices, and employees shall use these devices whenever
necessary to protect their health due to the nature of the
working environment.
b. Training Retirements; A minimum of six hours of initial
training and two to four hours refresher training annually is
to be provided to employees using respiratory equipment. The
training can be part of occupational safety and health training
for other reasons, and can count as credit for both programs.
Training topics include instruction in the nature of hazards;
explanation of the need for respirators; selecting the proper
respirator for the particular purpose; capabilities and
limitations of the device; instruction and training in actual
use, including fit and seal testing.
B. TRAINING MATERIALS AND SOURCES
1. Non-EPA Training
There are many health and safety courses available from
public and private sources. The Occupational Health and
.Safety Staff (OHSS) in Headquarters will review and approve the
content of such courses to meet the requirements of 1440.2
and 1440.3.
2. EPA-Developed Training
EPA has also developed health and safety training courses
for all employees who engage in field activities. For more
information, contact the person or organization listed below
each course, or consult the Regional Health and Safety Manager to
determine which course is suitable and satisfies applicable
training requirements under 1440.2 or 1440.3
a. OHSS-Developed Courses
(1) Basic Field Activities Safety Training fHazTrainl
(2) Safety and Health in EPA Field Activities (Steere &
Associates, Inc.)
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APPENDIX C
SUMMARY OP BASIC INSPECTOR CURRICULUM
Basic Inspector Curriculum
The Basic Inspector Curriculum encompasses five subject
areas needed for safe and effective conduct of compliance
monitoring inspections in all EPA program areas. Health and
safety, one of these key subjects, is covered separately in
Appendix B preceding.
A. Basic Training Course
The basic training course, covering the fundamentals of
environmental compliance monitoring inspections, integrates key
concepts and procedures from four subject areas and presents
these through a combination of classroom and self-study methods.
In addition, the curriculum explains EPA's enforcement
philosophy, the role of inspectors and compliance monitoring in
the administration and enforcement of environmental laws, and the
partnership between EPA and the States in assuring compliance,
particularly what is involved in oversight inspections with
States.
Legal. Includes overview of EPA's major environmental
Authorities statutes and enforcement authorities, the admin-
Requirements istrative and judicial enforcement processes,
;.' collecting and documenting evidence for
* enforcement proceedings, authority and require-
(> ments for lawful entry.
Technical Includes types of inspections, inspection site
Skills and selection, and pre-inspection planning and
Procedures preparation, recognizing and documenting
violations, sample collection and handling,
and overview of protocol and procedures for
oversight inspections.
Communi- Includes gaining entry, inspector as educator,
cations interviewing techniques, negotiations, and
preparation of inspection reports.
Administra- Includes pay administration, timekeeping, leave,
tive travel, and procurement.
Procedures
B. Health and Safety Training
The Basic Inspector Curriculum encompasses training required
in health and safety procedures and respiratory protection under
EPA Orders 1440.2 and 1440.3, respectively. They describe levels
of required training depending on the type of field work to be
performed.
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2
C. TRAINING MATERIALS AND SOURCES
1. Basic Training Course (OECM)
The course is designed in modular units that can be
presented either over a several-day sequence of time or in
individual units by in-house, experienced compliance and
enforcement staff.
Contact: Donna Fletcher
Compliance Policy and Planning Branch
Office of Enforcement and
Compliance Monitoring
U.S. Environmental Protection Agency
401 M Street, S.W. (LE-133)
Washington, D.C. 20460.
FTS 8-382-7550; E-mail code EPA 2281.
2. CERCLA Basic Training (OSWZR)
The Office of Solid Waste and Emergency Response is
developing a tailored basic course for On Scene Coordinators and
Remedial Project Managers which will be available in FY 1989.
Contact: Division Director
CERCLA Enforcement Division
Office of Waste Programs Enforcement
401 M Street, S.W. (WH-527)
Washington, D.C. 20460
FTS 8-382-4810; E-mail code EPA 5240
3. Health and Safety Training
Appendix B describes EPA-developed courses and materials
that are available to satisfy the health and safety training
requirements.
Contact: Regional Occupational Health and Safety Manager
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(3) Health and Safety Training for Compliance Inspector*
(Developed by OECM. Available FY 89)
Contact:
Regional Health and Safety Manager
or
Cherie demello-Zieschang
Occuptional Health and Safety Staff
Office of Administration
U.S. Environmental Protection Agency
401 M Street, S.W. (PM-273)
Washington, D.C. 20460
FTS: 8/382-3650
Commercial: 202/382-3650
b. .'fice of Emergency and Remedial Response (OERR)
Developed Courses
£ (1) Hazardous Materials Incident Response Operations
(Course #165.5)
(2) Personnel Protection Safety Training
(Course #165.2) '
£ Contact:
Superfund Training Regional Contact
:*' or
Registrar, OERR Training Program or
Thomas C. Sell, Training Coordinate or.
Jerome Joyce, Training Officer
U.S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, OH 45268
FTS: 8/684-7537
Commercial: 513/569-7537
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APPENDIX D
SUMMARIES OF PROGRAM-SPECIFIC TRAINING CURRICULA
Program-Specific Minimum Curricula
The Program-Specific Curriculum for each major environmental
program prepares inspectors/investigators to lead specific
types of inspections/investigations and to obtain information and
evidence in a technically and legally sound manner. The minimum
curricula can be implemented quickly and will undergo periodic
changes based on course evaluations and needs assessments.
Although some specialized curricula are available, Program
Offices will be developing materials over the next few years,
The need for specialized training will be determined by the
first-line supervisor in consultation with the employee. In
general, any inspector seeking such training should have
completed the Basic and Program-Specific Minimum Curricula or
their equivalent before taking specialized training.
Summaries of the curricula for the following programs are
found in Appendix D:
D-l. Air-Stationary Sources (^RiC#-&
D-2. Air-Mobile Sources
D-3.
D-4. National Pollutant Discharge Elimination System
(NPDES)
Comprehensive Environmental Response, Compensation an
Liability Act (CERCLA)
D-5. Pesticides/Toxic Substances (fft^Ll
D-6. Public Water Supply Supervision (JDotJ
D-7. Resource Conservation and Recovery Act (RCRA)
D-8. Underground Injection Control (UIC) (j)(jjj Oj
D-9. Wetlands Protection (U^\JtA-
iiis/c0 y^'-\ ^T
111 *- •• -^—- /
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APPENDIX D-l
AIR STATIONARY SOURCE INSPECTOR TRAINING PLAN
EXECUTIVE SUMMARY
Objectives and Scope of Inspector Training Program
p*
The Air Stationary Source Inspector Training Program
establishes a multi-level training curriculum for Agency
personnel engaged in stationary source compliance inspections. A
description of the training curriculum is presented in the
.Inspector Training Plan (ITP). The two major objectives of the
program are: 1) to ensure that every inspector gains the ability
to conduct a Level II inspection within six-to-eighteen months of
the initiation of training and 2) that experienced personnel have
the opportunity to take advanced courses in their area of specia-
lization to upgrade their skills and continue their professional
development.
The ITP focuses mainly on entry level training for new or
inexperienced inspectors to ensure a minimum level of expertise.
The training curriculum graphically depicted in Figure 1 shows a
progressive sequence of core courses, self-study and 6n-the-job
field training (OJFT) designed to provide the essential technical
skills and procedural knowledge needed to conduct routine
inspections of all but the most complex source categories.
* The training program is structured around three levels of
training. The first training, level, referred to as generic-
basirc, provides basic inspection knowledge and skills common to
any^Agency inspection function. The second training level,
termed program-minimum, provides those program-specific knowledge
and 'skills needed to conduct meaningful inspections of a wide
range of regulated air pollution source categories. The third
level of training consists of advanced specialized technical
training for more experienced inspectors to enable them to
perform highly complex inspections and compliance evaluations in
certain source-specific inspections areas. Although the current
training plan emphasizes entry level training (basic and prograx-
minimum), the plan will be expanded in the next phase to include
more program-specialized training and various training paths for
attaining more advanced inspection skills needed to perform Level
III and IV inspections and special engineering knowledge needed
to work more proficiently in certain types of sources.
Training Sequence and Completion Time
The training sequence for the generic-basic and program-
minimum level courses is designed to be completed in six to
eighteen months. The exact completion time deper—s on the amount
of the time that the new inspector spends on training activities
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and the educational background and prior relevant experience of
the inspector. The chart shown in Figure 2 illustrates the
approximate training time required for new employees without.
prior field experience. The chart.assumes completion of the
prescribed basic courses within nine months and the program-
minimum courses within eighteen months. Many elements of the
generic-basic training and the program-minimum training occur
simultaneously as was shown on the time-line in Figure 1.
However, EPA Health and Safety rules require that certain safety
courses must be completed before the inspector can perform any
field work other than supervised participation in field training
demonstrations.
The training curriculum described'in the ITP and outlined in
Figure 1 consists of at least 11 major training modules and is
estimated to require a total of 325 to 350 hours of course work
to complete. This is approximately 15 percent of the inspector's
available work time over an 18 month period. Compressing the
training schedule into a six month period, an option shown in the
training plan, will increase the percent time in-training to more
than 50 percent when averaged over the shorter time period. EPA
field supervisors, as a whole, strongly favor the accelerated
training option and are inclined to have new inspectors spend the
maximum time possible in training during their first few months
to prepare them to perform independent inspections and begin
contributing to the inspection workload at the earliest date.
Evaluating Training Needs and Developing Individual Training
Plans
The training program includes provisions for waiver of
certain program-minimum courses if the supervisor determines the
inspector already has the specific technical knowledge or skills
based on the employee's formal education and/or prior field
experience. A Supervisor's Training Evaluation Guide is being
prepared to assist supervisors in assessing the individual
inspector's training needs. After completing the generic-basic
portion of the curriculum which must be taken by all inspectors
without exception, each trainee would be evaluated to determine
any strengths, weaknesses or other critical gaps in the
inspector's education or experience background in order to
prepare an individual employee training plan. A supervisor's
decision to waive any of the prescribed program-minimum training
courses must be reviewed at a higher management level.
Training Delivery Methods
The training approach presented in the ITP advocates three
basic methods of training: 1) classroom courses, 2) formal on-
the-job field training, and 3) monitored self-study. A mix of
each type of training should be used depending on the most cost-
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effective training delivery method for a"specific subject area.
Some factor possibly affecting selection of the training
delivery method and source of training can be readily antici-
pated. First, other than during the initial start-up of the
training program, only small groups of inspectors will need to
take a given course at a time. Second, classroom courses must be
given frequently in order to move new inspectors rapidly through
the program. Also, Agency travel budgets will likely not allow
for extensive travel to training courses held outside the program
.operation area.
These factors strongly suggest that each Region should
develop good in-house training capability if the long-term -
inspector training program is to operate efficiently and cost-
effectively. Therefore, instructor training will be included in
the training program and development, of in-house training
capability will be encouraged.
Implementation of the Training Program
Hany of the core training courses described in the IIP are
not available at this time. Existing air training courses and
specialty compliance training workshops cover many of the topics
included in the proposed program-minimum curriculum and can be
used on an interim basis to implement the training program.
However, the training materials were generally developed for
other purposes and are not necessarily geared towards entry level
inspectors. In addition, the materials are not sufficiently
integrated with the other proposed training courses to offer a
thorough, well structured training experience or streamlined
enough to allow for completion of the_training sequence in an
optimum timeframe.
Therefore, included as an integral part of the ITP is a
multi-year training development effort that will provide the
training curriculum envisioned in the plan. The 3 to 4 year
phased development schedule described in the ITP will permit work
to begin immediately on the training areas of highest need and
gradually fill-in and upgrade course modules as resources become
available. A summary of the training development projects
appears in Table 1.
Extending Training to State/Local Agencies
The Agency inspector training and development program
initiative is basically intended to apply to EPA compliance
inspectors. However, it is recognized that State and local
personnel conduct the vast majority of compliance inspections
nationally under delegated or approved State programs and that
they require comparable training to perform their inspection
duties.
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The State and local control program officials consulted
during development of the Air Stationary Source Inspector
Training Plan expressed interest in adapting EPA's inspector
training courses for their own training purposes. Therefore, in
the design and development of the Air Stationary source Inspector
Training Program every effort, will be made to develop training.
materials that will have the widest possible application to all
agency inspection programs. States will be welcome to use all
relevant training materials and to participate whenever possible
in training opportunities arranged by the Regional Offices.
To assure that the training program is fully responsible to
the training needs at both the Federal and State/local program
level and to have the widest outreach and benefit to all control
agency inspection personnel, a Training Advisory Group has been
established to provide input throughout the planning and
implementation of the. program. Experienced compliance program
staff from EPA Regional Offices and State/local agencies have
been asked to serve as representatives. Their input is reflected
in the present plan.
Responsibility for Inspector Training
The Air Stationary Source Inspector Training Program cannot
be successful unless it has the assistance and support of all tr.e
various air program offices involved in the planning, direction
and the daily operation of the Agency's air compliance inspect ic.-.
activities. Responsibility for several of the more important
elements of the training program is discussed in the ITP.
The Regional Program Supervisors have ultimate responsi-
bility for assuring that inspector staff are properly trained ar.d
equipped to perform their inspection duties. The first-line
supervisors, in particular, will play a critical role in actively
working with each inspector to identify training needs, prepare
individual training plans and monitor the training.
The ITP emphasizes the field training portion of the
curriculum as much as the classwork. The Regional Offices will
have the responsibility for developing a structured on-the-job
field training (OJFT) program arid selecting and training OJFT
instructors. Although various training delivery options are
available it appears, the most practical approach for the Regions
is to develop a cadre of qualified in-house instructors for
presenting all of the basic generic and many of the program-
minimum courses. .The Regional Offices will also need to
designate persons to serve as focal points and coordinators for
implementing the program.
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The Stationary Source Compliance Division (SSCD) will serve
as the lead office for planning and coordinating the national air
inspector training effort. The Manpower and Technical
Information Branch of the Air Quality Management Division (Air
Pollution Training Institute) will provide logistic support and
assist SSCD in the program planning and development. These
functions will include developing and updating the program
•specific training curriculum, providing sufficient training
materials to do the training, conducting surveys of training
needs, coordinating the Air Training Advisory Group,, and
developing longrange training plans and supporting budget
requests.
Most of the generic-basic training courses will be developed
by- the Office of Enforcement and Compliance Monitoring (OECM).
OECM will provide instructor guides and up-to-date training
manuals and other instructional materials needed to carry out the
basic training. OCEM also has agreed to coordinate and oversee a
3-year Agency-wide evaluation of inspector training with the help
of the media programs.
Annual Assessment of Training Needs
i:
.:. The Stationary Source Compliance Program curriculum may
undergo changes fairly rapidly since it is a dynamic, technically
complex program that deals with a wide variety of emission
control regulations and regulated sources categories. To be
responsible to new and emerging compliance inspect-• on demands,
provisions are included in the ITP for developing new courses and
for periodic revision and updating of existing courses. This
will be accomplished through annual training needs surveys and
assessments, review of the training modules each year to correct
and replace out-of-date material, coordination with the program
offices on new control programs and regulations, and contact with
other EPA training groups and outside organizations.
Additional Information
For additional information contact: Division Director.
Stationary Source Compliance Division, Office of Air Quaility
Planning and Standards. 401 M Street, S.W., (EN-341) Washington,
D.C. 20460. FTS 8-382-2807.
-------
Heohh and Safety Refreiner (400)
Earflnt Start Dale
Program Spadalli ed Tialnlng —
Specially Couite 3
— jr ou(t«,
Ak Polhiton Sourcm. Control, and Regulation! (310)
Compliance, MonUorti 9. Biueflne (nipection
Technique*, end OJ1 (3?0)
VliWe
Eflloioeineni OK)
ln«p«cflon and Safety p50)
Mi PoOuOon lnip«c«an Saldy «n aB 1
IcW Enlui cement and Geneie) Sa'ety (?00)
Agervf Oilentalion (100)
\— Emhtlon Monitoring and Tetlng (340)
1 SMRi Develoomenl I?50I ' ^L™ Latetl Completion Dale
Progtam Minimum Tialnlng
.x— Laietl Compleilon Oele
IP Oenolet typical comte attendance dale
1 1 1 I 1 1 '
3 6 91? 15 >B 74
lime Sinco im i.idon ol ti.iinuiq. months
1 Itocodimendo i
once to' New I. mploycrs
-------
Table 1.
Training Development Projects
First Phase (Current fiscal year through 1989):
Agency/Air Programs Orientation Course
Basic/Program-minimum Safety Course Series
Asbestos Inspection Safety Procedures
VOC Surface Coating Industry Training Package
VOC Fugitive Source Inspection
VE/Opacity Enforcement Instructors Training Package
Combustion Source Compliance Evaluation
Environmental Statistics Review Course
Second Phase (FY 1989-1990):
Solvent Cleaning arid Solvent Storage/Handling Facilities Insp.
Air Pollution Sources, Control and Regulations
Process Emission Capture and Gas Handling Systems
Emission Monitoring and Testing
VOC Inspection Safety Procedures
•Third Phase (FY 1991-92):
Modifications to Program-minimum Courses
NESHAPS Organic Emission Standards and Air Toxics Source
Inspection/Evaluation Procedures
Class B VOC Source Compliance Monitoring and Evaluation Tech.
Solid and Liquid Waste Incinerators Inspection and Performance
Evaluation
Source Permit Drafting Techniques to Support Inspection
Program Activities
-------
100 _
_ 80-
o>
60-
o
O
o.
j| 40
o>
'£
5
20-
Laiest
Completion
Date
Genenc
Basic Training
LEGEND
On-the-Job Field Training
Self-Instructional
Classroom
Latest
Completion
Date
Program
Minimum Training
6-9 9-12 12-15 15-18
Time Since Employment (Months)
18-21
21 -24
Figure 2 Training Time Requirements lor Ne* Employees wunoui-Pr.or F.e'2 £«ce- e-»c(
-------
APPENDIX D-2
SUMMARY OF AIR - MOBILE SOURCE
INSPECTOR TRAINING PROGRAM DESCRIPTION
A. SUMMARY
The Air-Mobile Source Inspector Training Program establishes
a core program of self-study, coursework, and on-the-job training
(OJT). The Program training is intended for agency and non-
agency inspectors, the latter consisting of contractor, state ar.d
local personnel who perform inspections as official representa-
tives of the Agency. The purpose of the training.is to develop a
knowledgeable and effective field investigative staff who
understand the goals of the mobile source enforcement program,
the investigative techniques and data necessary to develop solid
enforcement cases, and the program's underlying policies.
This summary describes a series of basic skills that should
be acquired and relevant training/methodology oriented to the
type of inspections, i.e., Level I, II, or III conducted by the
Program. The training that is basic to all levels of inspections
is shown first, followed by skills and training that are unique
to the different levels of inspection. There is no established
time frame for delivery; training is done on an as needed basis.
: Figure 1 below shows the plan in summary fashion. To obtain
a copy of the complete "Office of Mobile Sources ,-ogram Specific
Inspection Training" contact: Richard Ackerman, Field Operations
and Support Division, Office of Mobile Sources (EN-397F), USEPA,
401 M Street, S.W. Washington, D.C. 20460. FTS 8-382-2643.
FIGURE 1
General Training for All Levels
Basic Skills Training/Methodology
Knowledge of EPA mission and general Self-study
Clean Air issues
Knowledge of applicable regulatory Self-study, classrooa
requirements and statutory provisions (Colorado State Univ.
and/or Univ of MI
course)
Ability to recognize violations of Classroom (EPA
applicable provisions lecture), OJT-24
hours
-------
Ability to collect, organize and present Classroom (EPA
investigative materials apropriately to lecture)
support enforcement action
Knowledge of criminal investigative Classroom (Glynco,
skills and techniques (limited to most GA)
senior EPA field personnel)
Training for Levels I and II
Basic Skills Training/Methodology
Knowledge of sampling techniques and • Classroom (EPA lee-
field testing and chain of custody ture),. OJT-40 hours
procedures
Understanding of investivative tech- OJT-40 hours, Class-
niques, inspection protocols, and inter- room EPA lecture)
action with regulated parties and the
public
Training for Level II
Knowledge of Mobile Source technology Self-study, classroom
and emissions effects (Colorado State Ur.iv.
ar.d/cr Ur.iv. of MI
course)
Training for Level III
Knowledge of refinery and importer OJT-120 hours, self-
records and audit techniques for study (contractor
lead phase-down investigation and prepared manual)
case development.
B. TRAINING MATERIALS AND THEIR SOURCES
The following materials are part of the Air-Mobile Source
Inspector Training Program.
1. Self-Study Materials
o Documents and publications on EPA mission, major clean
air issues, the federal motor vehicle emission control
program, and motor vehicle emission control technology
and emissions effects.
-------
3
o Applicable regulatory and statutory provisions.
o Textbook from University of Michigan's course "Combustion
Engine Emissions."
o Emission Controls Handbook from Colorado State University
training.
o General outline and flow chart for Level III audits.
Classroom Training
o University of > *chigan 40 hour course entitled "Combustion
Engine Emissi:..s." Deals with the theory of motor
vehicle emissions and the related control technology.
rresented once a year in Ann Arbor, Michigan and on
occasion presented to EPA employees in Washington, D.C.
j Criminal investigators training offered at the Federal Law
Enforcement Training Center in Glynco, Georgia.
o Colorado State University course entitled "Tampering
Detection Course." This is a 24 hour training session
presented by CSU staff and covering basic emissic control
technology, identification of vehicle tampering, and
associated inspection techniques.
o EPA lectures on inspection protocols, public interaction,
evidence gathering, and presentation of investigation
results; and on basic orientation for non-EPA inspectors.
o Training sessions offered when available by auto
manufacturers regarding new technology.
-------
APPENDIX D-3
SUMMARY OF CERCLA INSPECTOR TRAINING
[TO BE DEVELOPED]
The Program-Specific Minimum Curriculum for On-Scene
Coordinators (OSCs) and Remedial Project Managers (RPMs) who lead
compliance inspections/field investigations under CERCLA is
currently under development. When completed the program-specific
materials will cover the subject matter in the Basic Inspector
Curriculum as well as CERCLA-specific requirements.
As noted under Section 5.a. of EPA Order 3500.1, OSWZR will
provide additional program guidance to identify those OSCs and
RPMs within the CERCLA program who are performing work covered by
this Order. For additional information contact: Division
Director, CERCLA Enforcement Division, Office of Waste Programs
Enforcement, Office of Solid Waste and Emergency Response, 401 M
Street, S.W., (WH-527), Washington, DC 20460, FTS 8-382-4810;
E-Mail EPA 5240.
-------
UNJTED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
NCV 2 8 '588
SOUO WAST? AND
»eSPOSJ
MEMORANDUM
SUBJECT: Guidance on Applicability of EPA Order 3500.1 to CERCLA
Staff
FROM: Bruce M. Diamond, Directo
Of- 9 of Waste Programs
Henry L. Longest It, Director
Office of Emergency and Remedial
TO: Waste Management Division Directors
Regions I - X
Environmental Services Division Directors
Regions I - X
On June 29, 1988, EPA Order 3500.1 established training
requirements for Compliance Inspectors/Field Investigators. This
Order applies to all EPA personnel who lead or oversee the
conduct of compliance inspection/field investigations on a full
or part-time basis under any of EPA's statutes, including CERCLA.
However, since CERCLA staff do not perform classic
compliance inspections, the Order allows the CERCLA program
offices to define, through .guidance to the Regional
Administrators, which CERCLA staff shall be subject to the
Order's requirements, it also indicates that a CERCLA-specific
curriculum is being developed to address the required training.
The following definition shall be used to determine the
CERCLA staff subject to the Order's training requirements:
"All staff who collect samples, conduct field audits or
oversee Potentially Responsible Party (PRP) projects for the
purpose of ensuring PRP.compliance or for obtaining evidence to
use in potential enforcement actions."
-------
-2-
Thisi definition should include, at a minimum, On-Scene
Coordinator* (OSCs) and Remedial Project Managers (RPMs) involved
in fielo>activities. However, it is understood, per Section
9d(2) of the Order, that the Regional Administrator makes the
final determination of who in the Region is subject to the Order
and is responsible for reviewing and approving any exceptions to
the training requirements.
Curriculuip
In addition to the health and safety training currently
required, the Order mandates a minimum of forty hours that
cover:
o Legal fundamentals - introduction to enforcement of
statutes, overview of enforcement and compliance goals
and strategies, administrative and judicial litigation
processes, legal authority and EPA policies regarding
gaining entry, use of information-gathering tools, and
defining and documenting evidence
o Technical issues - roles and responsibilities of an
inspector/investigator, violation detection and
investigative techniques, records inspection,
statistical sampling strategies, obtaining physical
samples, QA/QC, and lab analysis
o cgmju,njcation skills - notification, negotiation
techniques, elements of an inspection plan, written
documentation & reporting requirements
\,
o Administrative -planning considerations, travel,
records management, organizational structure, contract
mechanisms
To meet these requirements, our offices will slightly
modify th« "OSC/RPM Basic Course". Additionally, the OSC/RPM
Support Program developed by OERR calls for an OSC/RPM Academy to
be pilots*, in April 1989 which will provide 41 days of required
trainine>Jror new OSCs and RPMs that will also meet, as part of
its currJQttlUB, the training requirements in EPA Order 3500.1.
At this time, it is not anticipated that any additional
training courses, or materials will need to be developed to meet
the Order's requirements.
If you have any questions about or problems with the
proposed definition of affected CERCLA staff or the curriculum,
please feel free to contact either of us.
-------
CERCLA IMPLEMENTATION
PLAN FOR INSPECTOR TRAINING ORDER
Product/Activity
Develop Guidance
on Applicability
of .Order to CERCLA
Staff
Modify OSC/RPM
Basic Course to
Meet Order Requirements
Develop draft
curriculum for
Superfund Training
Academy which also
addresses the training
requirements in Order
Finalize curriculum
for pilot Academy
Program
Schedule CERCLA-
Specitic required
training annually
and disseminate
this schedule to
all Regions
Conduct annual training
needs surveys
Evaluate Academy's
effectiveness
Address Order
Requirements in
future contracts
Who
Bruce Diamond, Director
OWPE
Henry Longest, Director
OERR
Debby Thomas
CERCLA Enforcement Divis
Meg Kelly
OPMT
OSC/RPM Support Program
Advisor's Group
Target
Completion
(Completed)
11/28/-
(Completed)
ion 12/15/88
(Completed)
10/21/88
Meg Kelly
OPMT
Meg Kelly
OPMT
Debby Thomas, OWPE
Jim Cruickshank
Training Coordinator,
OSWER
Henry Longest, Director
OERR
Meg Kelly
OPMT
Bruce Diamond, Director
OWPE
Henry Longest, Director
OERR
Bruce Diamond, Director
OWPE
(Completed)
1/18/39
On-going
On-going
On-going
After 1st
pilot in
May 89
will be
ongoing
9/89
-------
Deliver required Meg Kelly . . .
training OPMT Pilot
begins
5/89
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
Vl «0
-------
Superfund Training Academy
Session A
Proposed Schedule
Two Weeks
W
E
E
K
W
E
E
K
0
V
F
V
o
E
V
Sunday
Travel
Registration
Dinner
Cincinnati
Tour
Kcnday
Introduction (P)(E)
Overview ol
Supartund(P)
(CCICtASARA.
*— *
OSORPM Rotes
A RospomiWifes
(P)(E)
P4«CfMtfO«MMM^
Presentation
Shits IPHEI
Homework'
Case Study
Health
and
Safety
(P)(£)(AV)(D)
(PwtontMl PioMdmn
HMwdnMognkon.
Salary ProcMkMS)
Tueaday
Project
Managemenl
(PME)
S*i| lund Fibn
asl
i
Wednesday
Project
Managemenl
-------
Superfund Training Academy
Session B
Proposed Schedule
Two Weeks
D
A
y
E
V
0
A
V
E
V
Sunday
Travel
Regtslralion
Dinner
Site seeing
Homewoik
Monday
lnlroduction(P)(E)
Incident
Management
(PXEXAV)
c •)
Social Options
Legal
Fundamentals
(PXE)
1 >
Tuesday
SupertL
Inodenl
Managt
(P)(E)
i
ind Site/
•
tment
Case Study Group
**•- -*-
YVOfll
Legal
Fundamentals
(P)(E)
Contract
Administration/
Project Of licet
Training (P)(E)
(StvwtMrtCartiMM.
a^^Mt^rf^ui^Mrf Ar^^A f^
•wia^vnwra. rvm^v ••
Conkwlng P«oum«0
ItomewoiK
Wednesday
Site
Visit
Case Study Group
tmt-^A.
WOnl
Contoa<
Adrnmii
Protect
Tiainmi
1
:l
^ration/
Ofhcar
)(PME)
Honiewoik
Thursday
Supedund Silo/
Incident
Management
(P)
Community
Relations/Mock
Public Meeting
(P)(E)
(BM*gMun4. Skato«lM
M^flfMMMHH. AAO OOBI
PtagiMi.Pl.
*Mfteta*n
Case Study Group
Work
Conlrai
Adminh
Project
Training
1
:l
slralion/
Officer
> (P)(E)
Homcwoik
Friday
Legal
Fundamentals
(P)(E)
(fn*ore»n«r«
MMtMnkro.PHP
*» -^
•wora|
Case Study
Presentations
. Social Options
Contract
Administration/
Project Otlcer
Training (P)(E)
Overview ol
Cooperative
Agreements and
Superfund Slate
Contracts (P)(E)
k4M<* fPA/S4*>*.
o4*luM> « Pi*(*nl*llon |l ) i I ««ic!»« (AV) a Audlo»Uu»l (0) < U*man»H«lloo
-------
Superfund »>»«
KAv^MMMtN *AI0M1,
Homework
Negotiations/
Depositions
(PXEMAV)
(pt*K>9**mo*».
UHgOw«.l>f«««. .
otK*v«iri
.!
1 lUftMMWOtk
Thursday
Trealm
Technc
(P)(E)(I
•
enl
logics
3)
1
Homework
Risk
Assessment (E)
Risk
Communcation/
Crisis
Management (P)
(Community ftatatortt)
Homework
Negotiations/
Depositions
(P)(E)(AV)
i
Monu.-Mrork
Friday
Treatment
Technologies
(P)(£)(0)
i
1
Social Options
Field Tn
Headqu
i
Oebriel
p lo
arters
Social Options
Mock Deposition
Video Tapmg/
Feedback (P)(£)
(AV)
Luncn/SpeaKer
Wrap Up/
Ceflilic.il«>r>
Saturday
Homework
Sports/Shopping
Homework
Sports/Social
Options
Travel
w
E
K
W
E
E
V
w
E
E
V
|AV|
I / HI / li
-------
APPENDIX D-4
SUMMARY OF NPDES
INSPECTOR TRAINING PROGRAM DESCRIPTION
A. SUMMARY
The NPDES Training Program establishes a core program, of
coursework, self instruction and on-the-job training (OJT) for
those individuals who carry out NPDES compliance/enforcement
activities for EPA. This summry describes a sequence for new
inspectors, and for expansion of skills later on. After
completion of Basic Training and Introductory NPDES training,
self-instruct ion and OJT, the inspector should be able to conduct
the compliance evaluation inspection and the sampling inspection.
The goal is for each new inspector .to complete this sequence
within six to nine months on the job. Job skills can then be
expanded through more study and instruction into areas such as
performance audit, pretreatment,and diagnostic inspections.
The figure below shows the plan in summary fashion. In
order to get a copy of the complete NPDES Training Program
Description, contact: Director, Enforcement Division, Office of
Water Enforcement and Permits, HQ (EN-338), USEPA, 401 M Street,
SW, Washington, D.C, 20460. FTS 8-475-8488.
i NPDES Training Plan
Courses/Workshops
General Orientation
I Self Instruction /OJT
I
Program-Minimum
I
Basic Inspector Curriculum
NPDES Introductory Coursework
(Manuals available by 4/88)
CWA and Regulations
Violation Recognition
Sampling Techniques
Manuals for Introduction
to Compliance Inspections
Flow Measurement Manual
OJT« 2 inspections each
for compliance evaluation
and compliance sampling
inspections
svills Expansion
Pretreatment Inspection
Workshop
Diagnostic Inspection
Workshop
Pretreatment Guidance
Pretreatment Compliance
Inspection and Audit. Manual
Inspector's Guide for Evalu-
ating Municipal Wastewater
Treatment Plants
-------
Toxics Sampling OJT-Biomonitoring, toxics
sampling and pretreatment
inspections (to be developed)
(To be developed)
Specialized Skills
Offshore Drilling Rig Inspections
(to be developed)
Criminal Investigations (FLETC, Glynco, GA)
B. TRAINING MATERIALS AND THEIR SOURCES
The following materials for the new inspector should be
available from the inspector's first-line supervisor or the
addresses footnoted below.
o General Orientation Package
- Organization chart
- Clean Water Act and regulations
- NPDES Inspection Strategies and Guidance such as the Clean
Water Act Compliance/Enforcement Compendium
- Sample NPDES inspection reports
- Description of HQ/Regional/State relationships
- NPDES Compliance Inspection Manual
o Introduction to NPDES Inspections (Available 4/88)
- NPDES Compliance Monitoring Inspector Training Modules 1
— Overview (draft)
— Legal Issues (draft)
— Sampling (draft)
— Laboratory Analysis (under development)
Biomonitoring (under development)
Order I
- Field Manuals for Self. Instruction and OJT NTIS IRC2
— NPDCS Compliance Inspection Manual PB85115897 068U
— NPDES Flow Measurement Manual PB82131178/AS 050U
o Skills Expansion Coursework
^retreatment Inspections1
^-•atment Compliance Monitoring and Enforcement
—ov 1986)
lance Inspection and Audit
1 Authorities (July 1986)
us IRC2
— ins»r_ for Evaluation of Municipal 021U
Wastewater -_ :ment Plants, EPA/430/9-79-010
(April 1979)
-------
C. MAILING ADDRESSES:
1 Office of Water Enforcement and Permits, Enforcement Division
(EN-338) USEPA, 401 M Street, SW., Washington, D.C. 20460
2 U.S. Department of Commerce Instructional Resources
National Technical Information Center (IRC)
Service (NTIS) Ohio State University
5285 Port Royal Road 1200 Chambers Road, Room 310
Springfield, VA 22161 Columbus, OH 43212
(703) 487-4650 (614) 292-6717
-------
APR 2 |. ;339
OFFICE OF WATER ENFORCEMENT AND PERMITS
ENFORCEMENT DIVISION
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
INSPECTOR TRAINING PROGRAM DESCRIPTION
March 10, 1989
DEVELOPED IN CONJUNCTION WITH THE INSPECTOR
TRAINING AND DEVELOPMENT WORK GROUP
-------
Table of contents
Page
I. Introduction and purpose l
II. Description of training components i
III. Suggested sequencing of training 3
IV. Responsibilities for training 4
V. Feedback and updating training
description 5
Appendix
A. Detailed Description of Training for
New Inspectors A-..
B. Detailed Description of Training for
Experienced Inspectors < A-5
-------
NPDES INSPECTOR TRAINING PROGRAM DESCRIPTION
I. INTRODUCTION AND PURPOSE
This Program Description sets out a primary goal of a :or-a_,
structured approach to training of individuals vho carry out rrpris
compliance/enforcement field activities for EPA (hereafter -*r-^i
inspectors), wich a defined process for seeking Regional ideas >r.i
feedback on national NPDES inspector training activities, -or/or.:::?
and materials for national and regional training efforts. ~<~*
program described may also be of interest to states, and :- ±~
federal agencies, involved in NPDES inspection activities, ^s -.
national program it establishes a core program of course *->?••. •
self instruction materials, which regions may wish to supp.-r-e--
as the need arises.
This description is arranged to help answer the questions, ,-.\-
training is available, how is it delivered, and when is i:
appropriate? The detailed analyses of the training programs
for new and experienced inspectors are included as an Append:/.
for those --ho want greater detail. This training iescr:?-i:.-.
should be read in conjunction with the MPDES Inspector 7ra:.-.i.-7
Implementation Plan which contains detailed information sucn >;
lists of OWEP speakers, training materials available, and .order:--
information. The main sections of this Training Descript i :.-.
provide detail on training components, a brief skills analyse.
suggested sequencing of the training, a statement :.- ---
responsibilities for inspector training and a description :: - -
system for obtaining feedback on this system.
II. DESCRIPTION OF RECOMMENDED TRAINING COMPONENTS
Basic to the development of any training plan is a iis-:.-.- :•
the skills needed to conduct inspections. That Listing is —: --.
in Table I with a brief description of the type of training -.-•-.
could be used to meet the job skill needs of the inspector.
As can been seen in Tafcle I there are three basic methods *:
•deliver, training: course work, on-the-joo training (OJT) and -?: :
instruction. All three together play an important role in t.--?
training of the inspector. Table I presents the information :~
the target audience level, the type of training and general
time f ramie for the training. The detailed analysis of the tra:-. :
for new and experienced inspectors is described in greater de*. *.-
in the Appendix, pages A-l to A-8.
After completion of Fundamentals of Inspections Training -• :
NPDES Introductory training, self instruction and OJT for ---
inspectors,. the inspector should be able to conduct the compt:.v~-
evaluation inspection, the sampling inspection and then progr•»«?•»
to other inspections as for pretreatment. Thereafter he/she ->•
expand job skills into specialized areas such as performance .v. = : •
and diagnostic inspections.
-------
APPENDIX D-8
SUMMARY
UNDERGROUND INJECTION CONTROL
PROGRAM SPECIFIC INSPECTOR TRAINING
I. INTRODUCTION AND PURPOSE
The purpose of this UIC training program is to take a
structured approach to the training of UIC inspectors (those who.
conduct or oversee compliance and enforcement activities in the
field) to strengthen the effectiveness of their activities.
While the program is specifically applicable to EPA inspectors,
it may be of interest to States who conduct inspection in primacy
programs. As a national program it establishes a core of
essential training which may be supplemented as needed.
II. DESCRIPTION OF RECOMMENDED TRAINING COMPONENTS
The purpose of a training plan is to ensure opportunity for
every inspector to acquire and refine the skills and knowledge
needed to perform effectively. To that end, a set of experiences
should be made available over time including formal course work,
self instruction and on the job training.
Inspectors for the UIC program should be able to conduct
required field and monitoring activities and enforcement related
activities. EPA personnel, in addition, should be able to
provide oversight and assistance to State and contractor
inspectors.
Basic Inspector Training and UIC technical training, self-
instruction and on-the-job training are currently planned or
available for EPA inspectors. In addition, supplemental training
will also be needed to be developed to address new program areas
and enforcement needs.
III. SUGGESTED SEQUENCING
The sequence of training should be decided by the supervisor
in conjunction with the inspector, and after considering the
inspector's level of experience and the unique needs of the
Region. The sequencing should take advantage of the availability
of courses and the scheduling of inspections. In general, the
suggested sequence for all inspectors is as follows:
Orientation, Basic Inspector Curriculum, self study, technical
courses and on-the-job experience and training. For experienced
inspectors, training needs should be decided in consultation with
the first-line supervisor using the Supervisor's Guide to
determine if exceptions for training are appropriate. However,
it nay be desirable to attend the Basic Inspector Training
Curriculum and/or structured field training _j that EPA
inspectors have a common understanding with States and remain
-------
current with technical advances. Basic skills and knowledge
which all inspectors will be expected to acquire, and the
associated training experiences, are detailed as Attachment A.
IV. TRAINING MATERIALS AND THEIR SOURCES
The following kinds of materials for new inspectors should
be available from the .inspector's first-line supervisor.
o General Orientation
- Organization chart
- SDWA and regulations
- UIC Compliance Strategy
- Description of HQ/Regional/State relationships
- Applicable guidance and policy documents
- Inspection Manual (available FY 88)
o Technical Courses
- MIT Seminars (as available)
- Training Seminars
o Program Management Training
- (to be developed)
o Field Training
- (to be developed
-------
ATTACHMENT A
UIC Program-Specific Minimum and Specialized Training
SKILLS AND ASSOCIATED TRAINING
Basic Skill/Knowledge Needed Associated Training Experience
Knowledge of EPA enforce-
ment philosophy and stra-
tegies
o Basic Inspector Training
Ability to complete enforce- o Basic Inspector Training
ment fact gathering, with
understanding of ethics,
right of entry and inspec-
tor conduct
o Understanding of health and
safety requirements
o Health and Safety Training
o Understanding of the mission o Orientation (self study)
authority of the UIC program,
and enforcement strategies
Knowledge of basic UIC tech-
nical processes, causes of
noncompliance, ways to
improve operations in large
and small systems
A working knowledge of vio-
lation recognition, sampling
procedures and laboratory
analysis
A working knowledge off
applicable State programs
and procedures and ability
to provide constructive over-
sight
Knowledge of field con-
ditions and procedures
o Inspection Manual (self-
study) Inspection Manual
Training (TBD) Seminars1
o OJT
Special courses1
o Program Management Training
(OJT/self study)1
o Formal Field Training(TBD)1
•••specialized training as needed
-------
APPENDIX D-9
SUMMARY OF WETLANDS PROTECTION INSPECTOR TRAINING
[TO BE DEVELOPED]
The Office of Wetlands Protection is developing a Program-
'Specific Minimum Curriculum for inspections/investigations under
the wetlands protection program of the Clean Water Act, Section
404. OWP anticipates that the training materials and course will
be available during FY 1989.
For additional information, contact: Hazel Groman,
Enforcement Coordinator, Office of Wetlands Protection,
Regulatory Activities Division, 401 M Street, S.W., (A-104F),
Washington, D.C. 20460, FTS 8-475-8798.
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OFFICE OF WETLANDS PROTECTION
PROGRAM-SPECIFIC INSPECTOR TRAINING CURRICULUM
JUNE, 1989
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2
INTRODUCTION
Program Description
Section 404 of the Clean Water Act establishes a program to
regulate the discharge of dredged or fill material into "waters
of the United States," which includes most wetlands. EPA and the
Army Corps of Engineers jointly implement Section 404, with the
Corps responsible for deciding whether to issue or deny permits.
EPA, in conjunction with the Corps, develops Guidelines under
Section 404(b)(l) which contain the environmental standards that
the Corps must apply when evaluating permit applications. Under
Section 404(c), EPA has authority to prohibit or restrict
discharges if it determines that the discharge would have
unacceptable adverse effects on the resource. EPA's other
primary Section 404 responsibilities include defining the
geographic scope of Section 404 jurisdiction, applicability of
exemptions under Section 404(f), assumption of the program by
qualified States, and enforcement.
Section 404 enforcement differs from other Clean Water Act ;
enforcement programs in several ways. For one, EPA and the Corps.
share Section 404 enforcement authority. Sections 301 and 309 Of
the Clean Water Act give EPA the authority to act against persons
who discharge without a permit and also to enforce against
violations of Section 404 permit conditions. Section 309
provides EPA with a variety of enforcement mechanisms. Our first
line of defense is the administrative compliance order issued
pursuant to section 309(a), which generally requires a violator
to stop all illegal discharges and, where appropriate, to remove
the fill and/or restore the site. Section 309(g) authorizes EPA
to assess administrative civil penalties for, among other things,
violations of Section 404. A third enforcement mechanism allows
EPA to seek monetary penalties, injunctive relief, and even
prison sentences through judicial action pursuant to Sections
309_(b) and (c). Under these Sections, EPA may refer cases to the
Department of Justice for criminal and/or civil litigation.
Training Required by EPA Order 3500.1
EPA Order 3500.1, "Training and Development for Compliance
Inspectors and Field Investigators," establishes a consistent
Agency-wide training and development program for employees
leading environmental compliance inspect ions/ field
investigations. The Order mandates* both Basic and Program-
Specific training for compliance inspectors and their first-line
supervisors. The Office of Wetlands Protection has
responsibility for development of the Section 404 Program-
Specific training and curriculum. However, the Regional
Administrators and first-line supervisors of inspectors are
ultimately responsible for confirming that the training
requirements have been fulfilled. Responsibilities are discussed
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further in a later section. EPA Occupational Health and Safety
Training requirements are still in effect and will remain in
effect.
TRAINING CURRICULUM
Objective of Program-Specific Minimum Curriculum
This curriculum presents formal structure for training of
.individuals who carry out Section 404 dredge and fill compliance
inspection/field investigations for the Environmental Protection
Agency's (EPA's) Section 404 Program. There are three basic
components to the Section 404 Curriculum: (1) Self Study;
(2) Classroom; and, (3) On the Job Training (OJT) . These
components together play an important role in training of the
inspector and are described in detail at Attachment 1. A generic
description of the Basic Inspector Training Curriculum and Health
and Safety Training Order are also included in this attachment.
The curriculum described herein is considered the minimum
training for new and experienced inspectors and first-line
supervisors. OWP will conduct an annual review of the Section
404 Program curriculum (in consultation with the Regions) to
identify successes and shortcomings and how they can best be
addressed.
Applicability
.
s;, curriculum is applicable to all Section 404 Program staff
and ^first-line supervisors who conduct compliance inspection/ •
field investigations as defined by EPA Training Order 3500.1.
Specifically, this function applies to activities related to
compliance monitoring and enforcement; it does not include, for
example, field activities or investigations for purposes such as
research and development, which are unrelated to compliance
monitoring or enforcement efforts. New and experienced
inspectors and their first-line supervisors1 must meet all
requirements unless it can be demonstrated to their supervisor
that they have previous comparable training and/or experience
that meets the requirements of this curriculum. Separate
guidance entitled "Guidelines on Requirements for Exceptions to
OWP Program-Specific Minimum Curriculum for Inspector Training
Under EPA Order 3500.1" dated July 1989, explains how to assess
previous training and request exceptions. The general skills
that the compliance inspector should gain from the training, and
the methodologies used to attain these skills, are outlined in
Attachment 2 .
1 EPA Order 3500.1 defines new and experienced inspectors and
first-line supervisors at Section 5.(b), (c), and (d).
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Scheduling
New inspectors should complete the program-specific training as
soon as practicable once they are appointed to a Section 404
position with compliance inspection responsibilities. This
applies regardless of the percentage of time spent on these
activities. Experienced inspectors can also greatly benefit from
the training and should complete it as soon as scheduling allows.
Beginning October 1, 1989, new inspectors shall not lead
'inspections unless they have completed the Basic Curriculum, and
have completed, or have been formally excepted, from the Program-
Specific Curriculum. Beginning October 1, 1991, experienced
inspectors shall not lead inspections unless they have completed
or have been formally excepted from the Basic and Program-
Specific Minimum Curricula.
RESPONSIBILITY FOR DEVELOPMENT OP TRAINING AND CURRICULUM
Headquarters
The Office of Wetlands Protection (OWP) has responsibility for
development of the Section 404 Inspector Training Curriculum.
OWP has already offered with their contractor, the Environmental
Law Institute, a comprehensive two and one-half day Section 404
Enforcement Training Course in May 1989. Since OWP cannot now
commit to offer the training course on a regular basis, OWP will
use an enforcement handbook as an alternative training tool.
OWP's contractor is developing a comprehensive Section 404 case
development/enforcement strategy handbook, which is designed to
provide EPA Section 404 Program and legal enforcement personnel
with practical, step-by-step guidance and information on all
aspects of Section 404 enforcement. This handbook will be
available by September, 1989, for distribution to Section 404
Program personnel, ORC contacts, and representatives from other
Federal and State agencies. In addition, the May, 1989, National
Wetlands Enforcement Workshop Text used in conjunction with the
program-specific classroom training, is available and will serve
as a complementary training tool to the handbook. The points of
contact for the Section 404 inspector training curriculum, and
scheduling of national enforcement training course offerings are
Joseph OaVia and Hazel Groman (FTS 475-7799).
Regional Offices
The Regional Administrators and first-line supervisors of
inspectors have ultimate responsibility for assuring that
appropriate training is completed. As directed by EPA Order
3500.1, first'-line supervisors are responsible for setting up the
Individual Development Plan for each individual inspector.
First-line supervisors are also responsible for overseeing
certain aspects of the self study component in the Section 404
curriculum.
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GENERAL
Training Materials
The specific materials listed in each section of the Curriculum
should be made available to the inspector. The list of materials
may be substituted with comparable training material, or
augmented at the discretion of the first-line supervisor.
Continuing Education
The first-line supervisor may recommend additional training of
the inspector as deemed necessary. Additional training may take
the form of courses, self-instruct ion, or OJT with the first-line
supervisor or a more senior inspector.. This training will be
developed concurrently with new regulations, guidance, or
inspection procedures. Training needs will be monitored through
Regional reviews, and State input. OWP also welcomes suggestions
from inspectors, supervisors, and other enforcement personnel.
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ATTACHMBOT 1
SECTION 404 INSPECTOR
CURRICULUM
BASIC INSPECTOR TRAINING COURSE
Objectives;
Materials:
Methods :
To provide knowledge of the Agency's compliance
and enforcement process, and the roles inspectors
play in compliance monitoring and case
development;
To provide knowledge of the extent and limitations
of EPA's legal authorities to enter and inspect
facilities;
To provide knowledge of evidentiary requirements
and the procedures designed to assure that data
collected on an inspection will be admissible in
court;
To provide knowledge of good work practices
related to planning and conducting field
inspections, including technical and
administrative subjects and communications skills;
To provide knowledge of the requirements of a good
quality inspection report; and,
i
To provide knowledge of how to prepare for and
participate in enforcement proceedings such as
settlement negotiations, hearings, and trials.
Basic Inspector Training Course — Fundamentals of
Environmental Compliance Inspections Text
Classroom
Level of Effort: 32 hours
Objective:
Scope:
To provide a basic overview of EPA enforcement in
the context of the Section 404 Program and the
relationship to the U.S. Army Corps of Engineers
approach to permitting and enforcement.
Program Organization
Agency Philosophy and Policy on Enforcement
Role of Enforcement
Overview of Section 404 of the Clean Water Act
Overview of Enforcement Mechanisms
Overview of the U.S. Army corps of Engineer Regulations
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later ials:
- Headquarters and Regional Section 404 Organization Chart
- Sections 301, 308, 309, and 404 of the Clean Water Act
- Section 404(b)(l) Guidelines [40 CFR Part 230]
- Section 404(c)'Regulations
1-19-89 EPA/Department of Army Enforcement MOA
- 1-19-89 EPA/Department of Army Jurisdiction MOA
- U.S. Army Corps of Engineer Regulations
[33 CFR Parts 320-330]
- Section 404 Administrative Penalty Guidance
[ethods: Supervised Self Study (SSS)
,evel of Effort: Minimum of 16 hours
IECTION 404 PROGRAM-SPECIFIC CLASSROOM TRAINING
objective: To provide inspectors with the knowledge, skills
and ability to complete an effective Section 404
inspection.
icope:
.:_- Case Development
,~.; o Elements of a 404 case
-^-_ o Site access, entry
:;•* o Sources and types of evidence
o Waters of the U.S. delineation (including wetlands)
:-; o Aerial photography/Remote sensing
o Evidentiary considerations
o Expert witness
- Enforcement Authorities
o Options, Pros and Cons
- Enforcement Options
o Administrative — 309(a) and 309(g)
o Information Request — 308 Letter
o Civil Judicial
o Criminal 404 Case— Practice and Procedure
o After the Fact (ATF) Permit
- Referrals and Settlements
o EPA and DOJ
- Negotiation Skills
- Use of Media in the Enforcement Effort
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Materials:
- National Wetlands Enforcement Workshop Text - May 1989
+ Model 309(a) Administrative Order
+ Model 309(g) Administrative Penalty Complaint
+ Model 309(g) Consent Agreement
Section 404 Enforcement Handbook - September 1989
- Model 308 Information Request Letter
- Sample Litigation Report
- Model Press Release
Federal Wetland Delineation Manual
Methods: Classroom using Workshop Text (May 1989), and/or
SSS using Enforcement Handbook (September 1989) and
Workshop Text
Level of Effort: Classroom Training - 20 hours
and/or
SSS using Handbook and Text - 24 hours
SECTION 404 ON-THJB-JOB TRAINING (OJT1
Objective: To prepare for, and assist in, an actual Section
404 compliance inspection/field investigation with'
an experienced inspector.
Scope:
Develop inspection plan (or equivalent) by review of
appropriate file(s)
Prepare supplies, equipment, and travel schedule
Coordinate with other Federal, State, and local offices
In the field with the experienced inspector, further
develop knowledge of dredge or fill violations;
.inspection techniques; recordkeeping and reporting;
evidence collection; conducting opening and closing
meetings
Prepare an inspection report (or equivalent)
Materials:
. - sample inspection plan or equivalent
- Sample inspection report or equivalent
Method: Accompany experienced inspector on site visits
Level of Effort: A minimum of two compliance inspections/field
investigations at two different sites for
separate violations.
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HEALTH AKD SAFETY TRAINING
o Follow the applicable requirements of EPA Order 1400.2
This order establishes basic, intermediate, advanced
and refresher requirements for occupational health and
safety training for all EPA employees before enqaqina
in any field activities. y g
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ATTACHMENT 2
SKILLS AND RELEVANT TRAINING/METHODOLOGY
Basic Skills Needed Training Methodology
Knowledge of EPA enforcement
policies and strategies
Basic Fundamentals
Course, classroom
Basic understanding of general
.Section 404 dredge and fill issues,
applicable statutory/regulatory
requirements, legal, authority, and
Corps permit program
Knowledge of enforcement mechanisms
Supervised Self-study
(SSS), Classroom
Classroom, SSS
Working knowledge of wetland
delineation
Ability to recognize dredge or
fill violations
Knowledge of investigative
techniques, fact gathering,
inspection protocols, and
interaction with the regulated
community
Ability to collect, organize and
present investigative materials
appropriately to support
enforcement action
Knowledge of criminal investigative
skills and techniques
Knowledge/skills on health and
safety appropriate for site
investigations
Basic knowledge of wetland
characteristics: vegetation
soils, hydrology. [Necessary
background desirable but not
required]
Classroom, SSS, OJT
Classroom, OJT
Basic Fundamentals
Course, Classroom, OJT
Basic Fundamentals
Course, Classroom, SSS
Classroom
Health and Safety
Training
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APPENDIX E
SUMMARY OP RECOMMENDED
MULTI-MEDIA (MULTI-PROGRAM) TRAINING
Multi-Media (Multi-Program) Training is designed to foster
knowledge and skill in two or more compliance programs.
This training may occur for different compliance programs
under one environmental statute or under different statutes.
Preparation of this kind may be desirable, depending on the
resources and needs of each Regional Office. Having inspectors
with cross program training and experience would enable more
efficient use of travel time and money by allowing coordination
of inspections in a given geographical area. Also cross
training builds a flexible work force which can respond to
changing needs and changing resource levels. Decisions on the
appropriate mix and level of cross program training are at
the discretion of Regional Management.
A. Multi-Media (Multi-Program Inspection Screening Course
(Level 1)
This one-day course is designed to prepare compliance \ fi)° A
inspectors/field investigators to recognize and report on !- '/r x
obvious, key indicators of possible non-compliance in all
environmental program areas relevant to a particular facility
or site. The objective is to broaden the awareness of cross-
program" and cross-media concerns, thus enabling the inspector/
field investigator to be a more effective representative of
EPA as a whole. (This training would go beyond the overview
of all-enforcement programs in the Basic Curriculum.) Identi-
fication of non-compliance problems could result subsequently
in a full inspection(s) for one or more environmental programs at
the facility. The course would be most useful to employees who
already have experience with compliance inspections/field
investigations, and/or who spend a substantial portion of
their time e.g., 20% or more performing compliance inspections/
field investigations. OECM will work with the Programs and
Regions to develop this training course in FY 1989.
B. Multi-Media (Multi-Program) Inspection Training (Level 2)
This level of training means completing the required
Program-Specific Minimum Curricula (and specialized training,
if appropriate) in two or more Compliance Programs so that
the individual compliance inspector/field investigator is
fully prepared to .lead inspections in two or more programs
at a facility(ies). Regions are encouraged to support this
level of training where the relationship between the requirements
of two or more programs or the location of facilities makes
it cost-effective to do so.
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C. Multi-Media multi-Program) Team Inspection Training (Level 3
Depending or Regional Office needs and resources, a multi-
media (program) inspection which addresses all relevant
program retirements operative for a single facility may be
desirable. To support the development of compliance inspectors/
field investigators to lead such multi-media inspections
carried out by a team, the following training is recommended.
In addition to completion of the 1) Basic Curriculum, 2) Program
Specific Curricula in two or more Compliance Programs and
3) significant experience in leading inspections in more than
one program, specialized training in directing the activities
of a team inspecting a facility is appropriate. Such training
would develop organizational and supervisory skills and an
ability to grasp and.convey cross-program issues and
interrelationships. The National Enforcement Investigations
Center (NEIC) has provided multi-media training. Any request for
such training should be sent to Robert Harp, NEIC, Building 53,
Box 25227, Denver Federal Center, Denver, CO, 80225;
[FTS 8-776-5100; Commercial 303-236-5100.]
Each Region is encouraged to develop and train at least
one team leader for multi-media, team inspections/investigations,
and to decide where such inspections would have significant
benefits for deterring non-compliance.
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APPENDIX P
SUPPLEMENTAL TRAINING
1. Administrative Hearings/Trials; EPA Institute*
One-day course designed for technical and legal personnel
involved in administrative case preparation and presentation.
Covers types of administrative hearings, steps in the hearing
process, prehearing conferences, preparation of evidence and
witnesses, appeals.
2. Expert Witness; EPA Institute*
One-day course designed for EPA personnel who need an under-
standing of the legal process and/or who may serve as an
expert witness. Covers the legal system, anatomy of a lawsuit,
what to expect of depositions and of direct and cross
examinations at a trial.
3. Negotiation Skills; EPA Institute*
Two-day course designed for enforcement personnel. Covers basic
negotiation concepts,' planning for negotiations, tactics for
expediting negotiations, EPA position on issues commonly
found in settlement negotiations.
4. Criminal Investigations; Federal Law Enforcement Training
Center (FLETC)
The Federal Law Enforcement Training Center (FLETC) in Brunswick,
Georgia, offers criminal investigation training to EPA technical
personnel on an infrequent basis. In late FY '88 or early
FY '89, FLETC will present eight days of classroom instruct-
ion on recognizing and responding to criminal violations of
environmental laws. The course will cover subjects such as
developing sources of information, interviewing techniques,
search and seizure issues, and collection and protection of
evidence. Also to be covered are functions and services of
the Office of Criminal Investigations and laboratory and other
services of EPA's National Enforcement Investigation Center
(NEIC) and the Environmental Photographic Interpretation
Center. Classroom instruction will be augmented by crime
scene and courtroom practical exercises. Class size is
limited to 24. For additional information, contact Phillip
Andrew in Brunswick, Georgia, at FTS 8-230-2726.
* EPA Institute
For more information about individual courses (faculty, dates,
locations) or about the Institute, contact: Director, EPA
Institute, Office of Administration, 401 M Street, S.W., (PM-
224), Washington, D.C. 20460, FTS 8-382-2594, E-mail EPA3880)
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5. Automated Information Systems for Compliance Inspectors/
Field Investigators; National Enforcement Investigations
Center (NEIC)
NEIC will develop a one-day course for inspectors and
investigators to provide familiarity with the full range of
ADP support available to EPA and State personnel. The course
will cover EPA's Major National Program Compliance and
Enforcement systems as well as supplemental sources from both the
private and public sector. For more information contact Robert
Harp, NEIC, Box 25227, Denver Federal Center, Denver CO.
[FTS 8-776-5100; Commercial 303-236-5100]
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APPENDIX G
ACCOUNTABILITY POR INSPECTOR TRAINING
Ensuring that training occurs requires an effective
system of accountability within Headquarters and the Regions.
Without this, training for compliance inspectors/field
investigators may continue in a haphazard rather than a
consistent, continuing vay. This appendix contains a more
detailed list of the functions that need to be performed by
different organizations to effectively implement this program.
A. Headquarters* Responsibilities
1. AA for OECM. The AA for Enforcement and Compliance
Monitoring (OECM) or his/her designee is responsible for the
following:
a. Updating EPA Order 3500.1, overseeing and evaluating
implementation of the overall program requirements
and reporting to the Administrator and Assistant
Administrators;
b. c-ordinating a major evaluation of program impleroent-
< ion in three years vith the assistance of the Office
of Policy, Planning and Evaluation (OPPE);
c. Developing, updating and disseminating student manuals
and instructors' guides for the Basic Curriculum to
Regions and Headquarters;
d. Coordinating selection of instructors for the Basic
Curriculum, and maintaining a national list of
instructors from Regions and Headquarters;
e. Developing guides for first-line supervisors to use
in evaluating individual training needs and requesting
exceptions when applying the requirements of EPA Order
3500.1 vith respect to the Basic Curriculum;
f. Organizing a board of Senior Agency Managers and
inspectors/investigators from Headquarters and Regions,
to advise him/her in carrying out these responsi-
bilities;
g. Working with RAs and AAs to jointly recognize excellence
in compliance monitoring inspections/investigations; and
h. Assigning functions needed within OECM for implemen-
tation of these responsibilities and incorporating them
into the performance standards of responsible
individuals.
2. AA for OARM. The AA for Administration and Resources
Management or his/her designee is responsible for the
following:
a. Updating and providing sufficient materials for
occupational health and safety training, or approving
non-EPA courses to meet the requirements of EPA Orders
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1440.2 and 1440.3, >nd reviewing program-specific
health «nd safety training;
c. Vorking with OECM ar* the EPA Institute to coordinate
selection of instructors for Inspector Health and
Safety Curriculum and maintaining a national list;
(OHSS)
• c. Training EPA instructors in effective teaching
methods for the Basic Curriculum; (EPA Institute)
d. Working with Regions and Programs to evaluate
instructors' performance and provide useful
feedback; (EPA Institute)
e. Coordinating and disseminating a timely schedule
of classes for the Health and Safety, Basic and
Program-Specific Curricula, in consultation with
OECM, Program offices and the Regions using the
E-Train Information System; (PMD) and
f. Assigning functions needed within OARM for
• implementation and incorporating them into the
performance standards of responsible individuals.
3. AAs for Media Programs: Each Assistant Administrator or
his/her designee is responsible for the following:
a. Developing, updating and disseminating.materials and
schedules for classes under the Program-Specific
Curriculum(a), including advanced or specialized
training, in consultation with Regions and States;
b. Conducting surveys of Regions' and States' needs, and
periodic reviews of the entire Program-Specific
Minimum and Specialized Curricula;
c. Ensuring in future contracts and assistance agreements
awarded under the Senior Environmental Employment
Program, involving compliance inspections that
training is required by means of statements of work
or other appropriate vehicles;
d. Developing guides for first-line supervisors
to use in evaluating individual training needs and
in requesting exceptions when applying the require-
ments of this Order with respect to the Program-
Specific Minimum Curricula;
e. Assisting Regions by providing training delivery
contracts, or grants to university training centers
or other non-profit organizations for training delivery
where useful and effective;
f. For those programs with Headquarters-based inspectors,
or for OECM and NEIC, identifying who is subject to
EPA Order 3500.1 approving requests for exceptions for
these personnel, planning for delivery of the Basic
Curriculum and submitting a plan for this to OECM by
October 30, 1988. and incorporating training
requirements into position descriptions and performance
standards;
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g. Establishing standing work groups including Regions,
and States where appropriate, to help carry out
these responsibilities and to improve the quality of
the compliance monitoring function; and .
h. Assigning functions needed within the Media Program
Offices to implement this Order and incorporating
them into appropriate performance standards, such as
the general management standard.
B. Regions* Responsibilities*
1. RA. Each Regional Administrator is responsible for the
following:
a. Establishing an internal system, assigning functions
for implementation of the Basic Curriculum, and
submitting a plan that explains this operation to
OECM by October 30. 1988;
b. Determining who is subject to this Order and
maintaining records of those individuals and their
training accomplishments and/or exceptions;
c. Designating the DRA or a cross-Regional panel to
review and approve any exceptions to the requirements
of this policy;
d. Supporting in-house instruction for the Basic
Curriculum by working with OECM to identify Regional
personnel to serve as classroom instructors and keeping
. a current roster of trained instructors;
e. Scheduling the Basic Curriculum annually and
communicating it to OECM, OARM and other Regions;
f. Incorporating training requirements into position
descriptions and performance standards;
g. Ensuring in future contracts involving compliance
inspections that training is required by means of
statements of work or other appropriate vehicles;
h. Maintaining a sufficient supply of training materials
for Basic and Program-Specific Minimum Curricula
in the Region;
i. Ensuring each Regional program identifies States'
inspector training needs annually through the
State/EPA Enforcement Agreements process;
j. Assisting States in identifying ways to meet their-
training needs and coordinating training opportunities;
and
X. Assigning functions needed within the Region to
implement EPA Order 3500.1 and incorporating them into
appropriate performance standards.
*These responsibilities apply to any AA having cornliance
inspectors/investigators based in Headquarters such as the
AA for Air and Radiation for Mobile Sources Enforcement.
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2. Line Supervisors. Line supervisors, in Program or
Environmental Services Divisions, are responsible for the
following:
a. Ensuring quality compliance inspections/field invest-
igations using performance standards, periodic
appraisal, appropriate assignments to ensure
development, and recognition of personnel engaged in
the compliance monitoring function;
b. Working with each assigned compliance inspector to
identify training needs and to incorporate these
into an Individual Development Plan (IDP);
c. Preparing written requests for exceptions to EPA
Order 3500.1 and securing these in accordance with
procedures established in the Region or in
Headquarters;
d. Providing self-instruction materials and structured
on-the-job training experiences, and assuring that
assignments meet the requirements of this training
program;
e. Designating OJT instructors and preparing them for
this assignment;
f. Reviewing progress and maintaining records of indivi-
duals subject to EPA Order 3500.1 including their
accomplishments and/or exceptions;
g. Incorporating training requirements into position
descriptions and performance standards of responsible
individuals; .
h. Completing required training; and
i. Evaluating the effectiveness of training materials and
methods.
3. Compliance Inspectors/Field Investigators. Compliance
Inspectors/Field Investigators are responsible for the following:
a. Advising their supervisor about the history, and
extent of relevant training and experience, and
assisting in the preparation of an Individual
Development Plan (IDP) to meet the requirements of
EPA Order 3500.1;
b. Assisting in locating training courses to meet the
objectives of EPA Order 3500.1;
c. Evaluating the effectiveness of training materials
and methods;
d. If selected as an OJT instructor, planning and
preparing for this assignment; and
e.. Applying and maintaining the knowledge, skills and
techniques acquired through training to ensure that
inspections/investigations are accomplished in a
technically and legally sound manner.
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APPENDIX G
ACCOUNTABILITY FOR INSPECTOR TRAINING
Ensuring that training occurs requires an effective
system of accountability within Headquarters and the Regions.
Without this, training for compliance inspectors/field
investigators nay continue in a haphazard rather than a
consistent, continuing vay. This appendix contains a more
detailed list of the functions that need to be performed by
different organizations to effectively implement this program.
A. Headquarters* Responsibilities
1. AA for OECM. The AA for Enforcement and Compliance
Monitoring (OECM). or his/her designee is responsible for the
following:
a. Updating EPA Order 3500.1, overseeing and evaluating
implementation of the overall program requirements
and reporting to the Administrator and Assistant
Administrators;
b. C-ordinating a major evaluation of program implement-
i ion in three years with the assistance of the Office
of Policy, Planning and Evaluation (OPPE);
c. Developing, updating and disseminating student manuals
and instructors' guides for the Basic Curriculum to
Regions and Headquarters;
d. Coordinating selection of instructors for the Basic
Curriculum, and maintaining a national list of
.,i. instructors from Regions and Headquarters;
* e. Developing guides for first-line supervisors to use
% in evaluating individual training needs and requesting
exceptions when applying the requirements of EPA Order
3500.1 with respect to the Basic Curriculum;
f. Organizing a board of Senior Agency Managers and
inspectors/investigators from Headquarters and Regions,
to advise him/her in carrying out these responsi-
bilities;
g. Working with RAs and AAs to jointly recognize excellence
in compliance monitoring inspections/investigations; and
h. Assigning functions needed within OECM for implemen-
tation of these responsibilities and incorporating them
into the performance standards of responsible
Individuals.
2. - AA for OARM. The AA for Administration and Resources
Management or his/her designee is responsible for the
following:
a. Updating and providing sufficient materials for
occupational health and safety training, or approving
non-EPA courses to meet the requirements of EPA Orders
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1440.2 and 1440.3, Xnd reviewing program-specific
health «nd safety training;
c.. Working with OECM &r.- the EPA Institute to coordinate
selection of instructors for Inspector Health and
Safety Curriculum and maintaining a national list;
(OHSS)
c. Training EPA instructors in effective teaching
methods for the Basic Curriculum; (EPA Institute)
d. Working with Regions and Programs to evaluate
instructors' performance and provide useful
feedback; (EPA Institute)
e. Coordinating and disseminating a timely schedule
of classes for the Health and Safety, Basic and
Program-Specific Curricula, in consultation with
OECM, Program offices and the Regions using the
E-Train Information System; (PHD) and
f. Assigning functions needed within OARM for
implementation and incorporating them into the
performance standards of responsible individuals.
3. AAs for Media Programs; Each Assistant Administrator or
his/her designee is responsible for the following:
a. Developing, updating and disseminating materials and
schedules for classes under the Program-Specific
Curriculum(a), including advanced or specialized
training, in consultation with Regions and States;
b. Conducting surveys of Regions' and States' needs, and
periodic reviews of the entire Program-Specific
Minimum and Specialized Curricula;
c. Ensuring in future contracts and assistance agreements
awarded under the Senior Environmental Employment
Program, involving compliance inspections that
training is required by means of statements of work
or other appropriate vehicles;
d. Developing guides for first-line supervisors
to use in evaluating individual training needs and
in requesting exceptions when applying the require-
ments of this Order with respect to the Program-
Specific Minimum Curricula;
e. Assisting Regions by providing training delivery
contracts, or grants to university training centers
or other non-profit organizations for training delivery
where useful and effective;
f. For those programs with Headquarters-based inspectors,
or for OECM and NEIC, identifying who is subject to
EPA Order 3500.1 approving requests for exceptions for
these personnel, planning for delivery of the Basic
• Curriculum and submitting a plan for this to OECM by
October 30, 1988. and incorporating training
requirements into position descriptions and performance
standards;
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g. Establishing standing work groups including Regions,
and States where appropriate, to help carry out
these responsibilities and to improve the quality of
the compliance monitoring function; and
h. Assigning functions needed within the Media Program
Offices to implement this Order and incorporating
them into appropriate performance standards, such as
the general management standard.
B. Regions* Responsibilities*
1. RA. Each Regional Administrator is responsible for the
following:
a. Establishing an internal system, assigning functions
for implementation of the Basic Curriculum, and
submitting a plan that explains this operation to
OECM by October 30. 1988;
b. Determining who is subject to this Order and
maintaining records of those individuals and their
training accomplishments and/or exceptions;
c. Designating the DRA or a cross-Regional panel to
review and approve any exceptions to the requirements
of this policy;
d. Supporting in-house instruction for the Basic
Curriculum by working with OECM to identify Regional
personnel to serve as classroom instructors and keeping
. a current roster of trained instructors;
e. Scheduling the Basic Curriculum annually and
communicating it to OECM, OARM and other Regions;
f. Incorporating training requirements into position
descriptions and performance standards;
g. Ensuring in future contracts involving compliance
inspections that training is required by means of
statements of work or other appropriate vehicles;
h. Maintaining a sufficient supply of training materials
for Basic and Program-Specific Minimum Curricula
in the Region;
i. Ensuring each Regional program identifies States'
inspector training needs annually through the
State/EPA Enforcement Agreements process;
j. Assisting States in identifying ways to meet their
training needs and coordinating training opportunities;
and
k. Assigning functions needed within the Region to
implement EPA Order 3500.1 and incorporating them into
appropriate performance standards.
*These responsibilities apply to any AA having cornliance
inspectors/investigators based in Headquarters such as the
AA for Air and Radiation for Mobile Sources Enforcement.
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2. Lirie Supervisors. Line supervisors, in Program or
Environmental Services Divisions, are responsible for the
following:
a. Ensuring quality compliance inspections/field invest-
igations using performance standards, periodic
appraisal, appropriate assignments to ensure
development, and recognition of personnel engaged in
the compliance monitoring function;
b. Working with each assigned compliance inspector to
identify training needs and to incorporate these
into en Individual Development Plan (IDP);
c. Preparing vritten requests for exceptions to EPA
Order 3500.1 and securing these in accordance with
procedures established in the Region or in
Headquarters;
d. Providing self-instruction materials and structured
on-the-job training experiences, and assuring that
assignments meet the requirements of this training
program;
e. Designating OJT instructors and preparing then for
this assignment;
f. Reviewing progress and maintaining records of indivi-
duals subject to EPA Order 3500.1 including their
accomplishments and/or exceptions;
g. Incorporating training requirements into position
descriptions and performance standards of responsible
individuals;
h. Completing required training; and
i. Evaluating the effectiveness of training materials and
methods.
3. Compliance Inspectors/Field Investigators; Compliance
Inspectors/Field Investigators are responsible for the following
a. Advising their supervisor about the history, and
extent of relevant training and experience, and
assisting in the preparation of an Individual
Development Plan (IDP) to meet the requirements of
EPA Order 3500.1;
b. Assisting in locating training courses to meet the
objectives of EPA Order 3500.1;
c. Evaluating the effectiveness of training materials
and methods;
d. If selected as an OJT instructor, planning and
preparing for this assignment; and
e. Applying and maintaining the knowledge, skills and
techniques acquired through training to ensure that
inspections/investigations are accomplished in a
technically and legally sound manner.
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TABLE I
SKILLS AND ASSOCIATED TRAINING
Basic skin/Knowledge Associated Training
Needed Experience"
Entry Level- usually course work (classes) and self ins true-: zr.
within first. 3 co 6 montns ; OJT first 6 to 9 months. «( Indiv; ^-.: ^.
as hired generally have basic knowledge of engineering, CMST: 5- .-
or biology. Remedial training for other individuals can be arra.-.re
through local colleges and universities.)
o knowledge of EPA enforcement phil- fundamentals of
osophies and strategies Inspections
Training Cci~>
o ability to complete enforcement fact
gathering, with understanding of ethics, FIT
right of entry, and inspector conduct
.6 knowledge/skills on health and safety Health and Safe-.y
appropriate to the encountered and training
facilities entered
o basic understanding of the mission • MPDES Introductory
and components of NPDES program - 30 hr. class
o understanding of the duties and re- NPDES Intrciur-.:.-.
sponsibilities of the NPDES inspector Training
o understanding of the legal authority :JPDES Introduc-.:.-.
for NPDES program,in relationship to Training
water quality standards, effluent
guidelines, and NPDES permits
o minimum knowledge including basic NPDES Introduc.sry
wastewater treatment, sampling pro- Training
cedures, flow measurement, and lab-
oratory procedures
o working knowledge of essential
violation recognition, evaluation and OJT
documentation fundamental to all
inspections
o reasonable knowledge of basic wastewater
treatment process control and quantitative OJT
observation/measurement
o reasonable grounding in the basic con- NPDES Introductory
cepts (so the inspector can assist) in Training
the areas of: pretreatment, biomonitoring
and performance audit
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Basic Skill/Knowledge Associated Training
Needed Experience
o knowledge of sampling techniques, field OJT
calibration and use of measuring devices
Skills Expansion Mfor experienced
inspectors, who know tne basics
buc nead axilla expansion or update)
o knowledge of pretreatment Workshop (8 hr)
compliance inspection and OJT
duties and responsibilities
o knowledge of diagnostic Workshop (16 hr)
inspection duties, &. treatment and OJT
techniques
o reinforcement of .basic skills . Self instruction or
specific where the supervisor refresher course
determines there is a need where appropriate
o Knowledge to perform biomonitoring OJT, self instruction,
and performance audit inspections Regional workshops
o knowledge of procedures OJT and self study
o toxics sampling inspections OJT and self study
Specialized skills (optional for experienced
inspectors needing specialized skills)
o knowledge of procedures and Classroom training
requirements for criminal investi- (Glynco, GA)
gations
o knowledge of how to plan and OJT & possible Course
conduct offshore drilling rig material being
inspections developed
o skill in conducting oversight OJT
inspections (meaning evaluating
inspections conducted jointly
with another agency)
o skills in teaching and preparing Course - EPA institute
classroom presentations
(To maintain skills, an inspector may need refresher training
certain areas above as determined by the supervisor.}
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The latter skills In Table I would be developed primarily ..--
classes, workshops and OJT. As the inspector becomes -:.-•?
proficient, he/she can take the lead on specific types ::
inspections. As skills become rusty, as observed :n -.--?
performance evaluation process, or as technology advances •- :
statutory and regulatory requirements change, refresher tra:.-..r:
may se needed.
III. SUGGESTED SEQUENCING OF THE INSPECTOR TRAINING
The supervisor should prepare Individual Development ?:j.-.-, •
(IDP) for new NPDES inspectors, considering the unique needs ::
the Region and the experience of the individual inspec-:.- :
position. Several Regions have pointed out .that emp;c
especially new ones, should have IDP's which .utilize
instruction, only in conjunction wich interactive 'instruct ::.-
in courses (classroom training), and controlled or supervised
Self .rtstruction alone is not sufficient. The sequencing of -.
NPDES inspector training must take into consideration
.availability of courses and workshops and the scheduling
inspections (for OJT). The suggested sequencing is included
Table I. The training sequence is arranged oy category -:
introductory items coming first (generally taking place dun
the first few months unless excepted because of the experience
the inspector). Then for inspectors who have attained -
ability to complete compliance evaluation inspections
compliance sampling inspections, there should be skills expa-
training for other types of inspections as the need of the =-?--.
dictates. In addition, optional training .-nay be useful -..-.: .
not every inspector or every Region may need tnis. The foil:-.
paragraphs describe the sequencing of specific phases
inspector training.
Introductory Training
The FIT training should be taken by all new inspectors.
as soon as possible after being hired. Supervisors provide '.-?'.
Introductory materials to new inspectors for their -.-2
instruction and OJT training. Regions often provide workshops
Introduction to NPDES inspections for new inspectors. <:•.
recommended that all introductory course work and workshops
provided within the first six months.) Self instruction and
on the basics can be excepted if the new inspector r.as -
experience with NPDES inspections and meets the NPOES cj.
skills evaluation in the supervisor's guide (to be developed).
Skills Expansion Training
After the inspector has had the FIT and NPDES Introduc-^- •
training and mastered the basic skills, the inspector may se-=<
more specialized training in Diagnostic Inspection
Pretreatment Compliance Inspections. The NPOES inspectors =;"
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nave the course work or self- instruction and OJT in spec •. a.; -^^
inspections before they take the lead in conducting tnem. ;^
addition, self instruction and OJT can be used by the superv.se:"
to update or improve the expertise available in the region.
Specialization Training (to be developed)
The degree of skills accumulation in specialized acriv. -:-=s
is often dependent on the inspector's experience, academic
background, aptitude, personal'mot ivation, and the needs ~: ---?
program. The supervisor or inspector may wish to identify -. r^.--
ing in specialized areas depending on the needs of'the reqi:-. .
program. The inspector may need to develop skills in c r ; n i.-i .
investigations, and oversight inspections. More exper s.e.nce'i
inspectors may consider training in communication skills as -.-•?•.-
begin to pass on their, expertise to new inspectors. Topics -i.
eventually include offshore platform inspections.
IV. RESPONSIBILITIES FOR INSPECTOR TRAINING
Office of Water Enforcement and Permits
The Director of the Office Of Water Enforcement and Perni'tj
(OWEP) will take responsibility for developing program-spec ir'ic
training materials, modules and manuals to back up the trai~i--
efforts of the regions. The materials which are available ....
be listed in the NPDES Inspector Training Implementation ?ii-
which is updated every year and is available from Enforcerer-
Division, OWEP, EN-338. In addition, OWEP will coordinate •-.-*
NPDES Inspection Materials Work Group effort to review and ivi.--
in development of training materials, both newly dev«.:--?:
material and revised materials. In addition where tr.er* . s
sufficient need, OWEP will offer Annual contract supper- :-.r
delivery of skills-expansion workshops such as for co.~p:.i.- :•?
Diagnostic. Inspections and Pretreatment Compliance ins pec-.. :~v
As the need arises, OWEP can provide speakers on specific -:p.:s
such as biomonitoring inspections, pretreatment inspections \--i
enforcement and discharge monitoring report quality assurance.
Regional Offices
Regional Administrators and supervisors have ultimate
responsibility for assuring time is set aside for training :-'
inspectors and for carrying out Individual Development ? • =•
(IDPs). Responsibility for setting up the IDP for • indiv.-..«.
inspectors/positions rests with the first line supervisor.
addition "the supervisor provides basic manuals, modules
copies of the Act and regulations to new employees. Infor-a-..-
on courses will be available in'. EC ATS and other schedules
classes/workshops. Information on how to locate and obtain :-;.->-
of manuals and modules related to NPDES inspector training :<
-------
- 6 -
found in the NPDES Inspector Training Impiementat icn ? la-
available from Enforcement Division, OWEP (EN-338). •?-;•.:
instruction and OJT may be overseen by more exper :=.-.<:n
inspectors. Experienced inspectors also can provide excel:?.-.-.
instructors for regional workshops such as for the Introduce: :r.
no N'PDES Inap«ctiona as well as other regional workshops. Tr.e
regional training otticmr may b« ua«d as a resource to locate
courses and training materials.
In. addition individual experienced inspectors win be sr.t.--.
by OWEP to serve on the NPDES Inspection Materials wor< :r: .p
which win periodically review and comment on training mater:5.3"
NPDES Inspectors
Once an IDP is in place it is the responsibility of cr.^
inspector to help in locating courses to satisfy or fulfill -.-•;
IDP, and to attend classes, workshops and satisfactorily complete
the required reading, self instruction and OJT assignments.
V. FEEDBACK FOR UPDATING THE NPDES INSPECTOR TRAINING
Once a year in preparation for the coming fiscal year, tr.e
Director of the Office of Water Enforcement and Permits will ;-=•?<
information from the regional offices on their training nee'-!*
the coming year, including training materials, delivery :
workshops by contract and need for specific speakers. OWE? .. .
also) at least every two years seek ideas from the Regions ar.± ---?
NPDES Inspection Materials Work Group on future instruct.:-i.
material and modules, and needs for specific course vork. "-•?••>
comments win be used to determine priorities for development .:
new ^training materials and courses- or revision of exis-::-;
training materials and courses.
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APPENDIX
-------
DETAILED DESCRIPTION OF TRAINING FOR NEW INSPECTORS
1) Objectives: Fundamentals of Inspections Training (FIT)
- classes
To understand the "standard basic skills
for flald Investigations
NPDES Introductory Training (Classes/Self
Instruction)
To obtain a basic overview of the mission
and components of the NPDES program
To provide a more comprehensive
understanding of Clean Water Act and :-JPDES
legal authorities
To provide the new inspector with basic
technical and sampling knowledge to allow
OJT in the field with more senior inspectors
NPDES OJT for new inspectors:
To develop working knowledge of fundamentals
of violation'recognition, evaluation and
documentation fundamental to all types of
NPDES inspections
To develop a reasonable comprehension of
basic wastewater treatment processes and the
ability to make observations and
measurements
To become knowledgeable in proper analytical
procedures and record keeping requirements
To gain field experience with the proper
calibration and use of measuring instruments
and sampling techniques
2) Assump- The newly hired employee will have any required
tions: health and safety training required by EPA order.
This and FIT training occurs before performing
field work. The self instruction in NPDES basics
may be concurrent with or before the field work.
3) Audience: New inspectors doing NPDES inspections
A-l
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4) Content:. FIT training:
This win include all information that an
inspector will need regardless of the program
he/she works in. Some topics include: basics of
safety, communications, administrative
procedures, litigation process, witness
guidelines, and ethics.
Self instruction study material for the new
inspector should include in an orientation package:
o Organization chart
o NPDES Inspection Strategies and guidance sue-
as the Clean Water Act Compliance/Enforcerrer.r
Compendium.
o Sample NPDES inspection reports
o Descriptions of HQ/Regional/State relationships
o Introductory NPDES Inspection Training Modules
o MPDES Compliance Inspection Manual
o The Statute and regulations
o NPDES Flow Measurement Manual
The content for OJT includes but is not limited to
the following:
In the office, the new inspector should go
through the preparation for an inspection by
developing the inspection plan: by reviewi.-q -.-•?
compliance/permit files, including self monitor:-.;
reports, correspondence, administrative orders >.r.±
permit applications. In addition, the inspect:r
learns to prepare supplies, equipment and travel
schedule and arranges coordination with the
laboratory, state and other programs.
In the field, the inspector learns while
accompanying an experienced inspector on at lease
2 inspections- 1 municipal and 1 industrial, ror
each type of inspection (for at least the
compliance evaluation and compliance sampling
inspection and other inspection types as
determined by the supervisor) to develop knowledge
in processes, pollution control equipment
operation, inspection techniques, interpretation
of data, record keeping and reporting,
evidence collection, analytical procedures and
basic measurements and abatement strategies. The
inspector also gains knowledge in conducting
opening and closing conferences.
A-2
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5) Materials
available:
6) Training
Method:
The new inspector learns in the field by
observing, asking questions, and document ir.g
events of each inspection. .»e/she may:
o record a summary of items learned from the si.e
field visit.
o prepare an inspection report based on Mis or
tha lead inspector's field notes.
o Gain hands-on field experience in proper
calibration and use of necessary instrurr.er.es
and sajnpling techniques
Suggested progressive sequence of field era:.-...-.
o Make observations and write them up
o Focus on individual components of inspect:cr.
as file and records review, sampling
procedures, use of measurement devices, and
writing inspection reports
o work on particular types of inspections and
areas of weak experience
o Finally take the lead with an experienced
inspector and then go unaccompanied on •:.-.iz-?:
tions
Basic Inspector Training: Manuals and Regiorra.
materials as follows:
NPDES Introductory training:
o Organization chart
o NPDES Strategies and guidance such as tr.a-. .
the Clean Water Act Compliance/Enforcement
Compendium
o Sample NPDES inspection reports
o Descriptions of HQ/Regional/State
relationships r
o NPDES Introductory Inspection Modules
o NPDES Compliance Inspection Manual
o Statutes and regulations
o NPDES Flow Measurement Manual
NPDES OJT: NPDES Compliance Inspection Manual
FIT: courses or self instruction
NPDES Introduction - Class/Self Instruction:
A-3
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7)Hours/Level
of Effort:
8)
Timetable/
sequence:
9)
Required/
Recom-
mended :
Reading material on one's own, witn one on c.-.e
discussion or class with more experienced
inspectors. (Regions may use a class/vorksncp
format if there are a sufficient nuraber of r.-ev
hires.)
NPDES OJT: OJT is used in combination vith se.
instruction to develop more complex skills.
FIT: about 40 to 80 hours
NPDES Introductory Course work: An average
of 30 hours for class and on average of 80 hours
for self instruction.
NPDES OJT: An average of 100 hours. Must
have minimum number of OJT inspections before
taking lead on inspections (see Item 4 above).
FIT: within first 3 to 6 months of being assigned
inspection duties.
NPDES Introductory training: Materials for self
instruction should be given to the new inspector
within the first month of employment and usually
before or in conjunction with FIT or program
specific training. (HQ recommends having all
introductory courses or workshops during the ::.-;-.
six months of employment.) The self instruction.
generally occurs before OJT in the field.
NPDES OJT: OJT should occur during the first year
and often along with self instruction and courses.
FIT: For new employees, no exception
NPDES Introductory Course work: Required
NPOES OJT: Required especially the field OJT
before performing inspections alone or as the lead
inspector.
Exception conditions: No exceptions for those
newly hired into EPA. The NPDES Introductory
class/self instruction, and OJT may be excepted '::
performance/experience can satisfy the
requirements, by meeting the evaluation the
reviewing official or regional peer review board.
A-4
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10 '
FIT: Testing in some form.
„„
A-5
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DETAILED DESCRIPTION OF TRAINING FOR EXPERIENCED INSPECTORS
l) Objectives:
2) Assumptions:
3) Audience:
Course work (generally workshops): To provide1
increased understanding of components of the
NPDES inspection program for more specialized
types of NPDES inspections.
Self instruction: To provide refresher
training for brushing up on skills where the
inspector fails to demonstrate adequate
maintenance of skills, with concentration on
subjects which are weak areas. This
demonstration could be by poor
on-the-job performance for instance (See Item
10 on page A-8 and the Supervisor's Guide).
Self instruction is also used to prepare the
employee for OJT for more complicated types of
inspections using'modules and manuals available
from OWEP (See Section 5).
OJT: To develop more specialized knowledge of
various types of inspections such as biomonit-
oring, toxic sampling and performance audit.
To develop an increased comprehension of
various types of wastewater treatment processes
and ability to maJce detailed evaluations of
laboratory analytical procedures and quality
control activities.
To gain field experience in the proper use of
complex sampling and equipment techniques.
Completion of the introductory level study, and
some field experience on basic inspections
(compliance evaluation and sampling
inspection).
Course work: Training site will be the
regional office with trainers provided by the
region or through national contract.
Self instruction: Materials are provided by
the region to the inspector.
OJT: Any needed self instruction or course
activity is completed prior to OJT.
Experienced inspectors who have completed the
basic courses and study and have had some field
experience.
A-6
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4) Content: Course work: Specialized courses and skills
expansion workshops such as; Pretreatment
Compliance Inspections, and Diagnostic
Inspections. Selection of courses depends on
regional need. A course on techniques and
skills for instructors is available through
the EPA Institute.
Self instruction: Materials currently available
include the Pretreatment Manual. Material for
refresher self instruction include the NPDES
Inspection Training Modules, and current inspect :cr.
manuals,-Statute and regulations as well as policy
and guidance binders.
OJT: Learning in the field occurs by accompanying
experienced inspectors on biomonitoring,
performance audit, pretreatment or diagnostic
inspections.
5) Materials Course work: A manual/ workbook is available which
may vary from year to year.
Self instruction: See above in Item 4.
OJT: Manuals such as the NPDES Compliance
Inspection Manual and the Pretreatment Inspection
Manual.
6 ^Training
^Method:
Course work: The instructor is an experienced
inspector or contractor in a workshop or seminar
setting, generally in the regional office.
Self instruction: Introductory NPDES Inspector
Training Modules (to be available March, 1988), and
current manuals such as the NPDES Compliance
Inspection Manual, the Act and regulations. (It is
assumed that an experienced inspector is available
to answer questions.)
OJT: OJT generally follows self instruction or
courses with OJT primarily in the field with an
inspector experienced in the type of inspection
being studied.
7) Level of
Effort:
Workshops require 8 to 24 hours.
Self instruction: No set limit or minimum required
hours. Refresher training in particular will vary
with the subject and with the individual.
A-7
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OJT: The number of hours needed will vary •-• :.-.->. cr.e
type of inspection. For each type of inspection
studied, at least two OJT inspections (with'the
inspector assisting) are recommended before he/sne
performs an inspection alone or in the lead.
8) Timetable/
Sequence.
9) Required/
Compliance
Recommended:
10.) Testing
In general, this training may occur at ar.y
time, after the inspector has completed tr-.e
basic instruction, and has had some field
experience with basic inspections.
Course work: The -inspector preferably win r.ave
courses before OJT in the field.
Self instruction: self instruction generally
takes place before OJT in the field.
OJT: The OJT in field generally win occur
after course work or self instruction.
Course work: Workshops in Pretreatnent
Inspections and in Diagnostic Inspections are
recommended before inspectors conduct these
inspections.
Self instruction: Self instruction and
refresher training is required for all
inspectors.
OJT: Inspectors are required to have OJT
before taking the lead on inspections.
Exceptions: Employees with experience in NPDES
inspections of a particular type may be
excepted from that particular courses and self
instruction. No exceptions are allowed from
refresher training where there is a
determination that this is necessary.
Testing as part of a workshop or other tratr. :".q
can provide feedback to the inspector, trainer.
and supervisor on knowledge gained.
A-8
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APPENDIX D-5
SUMMARY OF TOXIC SUBSTANCES/PESTICIDES PROGRAM TRAINING
A. SUMMARY
This training plan describes the required core and specialized
training for TSCA/F.IFRA inspectors. It describes both the basic
requirements for new (i.e., either new to the inspection function
or new to OPTS) inspectors and specialized courses which are
required only for personnel who will be conducting inspections in
particular program areas (e.g., GLP inspections, asbestos
inspections, etc.). Both designated new and experienced
•inspectors will take the specialized training.
After completing the TSCA/FIFRA overview and basic TSCA
inspection procedures (both within the first two months on the
job) and the OECM Basic Curriculum (within the first six months),
OPTS inspectors will be ready for a series of OJT and program
sub-speciality training and activities.
In order to get a copy of the complete description of the
TSCA/FIFRA training program, please contact Mike Wood, Chief,
Compliance Branch, Office of Compliance Monitoring, USEPA, 401
M Street, SW, (EN-342), Washington, D.C. 20460, Rm E-715,
FTS 8-382-7835.
The schematic below shows the plan in summinary fashion.
- TSCA/FIFRA INSPECTOR TRAINING
I. Program-Minimum
Training Method of Instruction Timing
A'
1. TSCA/FIFRA intro/ mostly self-study 80 hrs. within
orientation first two months
(required unless on job
has equivalent
training)
2. Basic TSCA/FIFRA mostly self-study 10 hrs. within
Inspection (some lecture) first two months
Procedures on job
(required)
3. OECM Basic coursework or up to 80 hrs.
Curriculum equivalent (depending on
(required or individual) within
equivalent) first six months on
job
-------
Training
4. OJT Office
Preparation
to prepare
inspector for
field work
(required)
5. OJT Field
Experience
(recommended)
Training
6. OJT Inspections
(recommended)
7. TSCA/FIFRA
Case Preparation
Procedures
(recommended)
Method of Instruction
supervised OJT
Timing
20-60 hrs..
(depending on
individual) prior
to first field
inspection
3-6 supervised
OJT inspections
as a junior inspector
solo inspection at
5-10 facilities
(Supervisor evaluates
inspection report)
classroom (lecture),
case studies
II. Specialized Training
Section-specific
detailed training
(required for
designated
inspectors)
Seminars, Workshops,
and individually-
designed training
sessions
8-32 hrs. per
inspection within
first six months
on job
Method of Instruction Timing
8-45 hrs. per
inspection after
completion of
1,2,3
estimated 24 hrs.
(taken as offered)
2-32 hrs. depen-
ding on the sec-
tion-specific
training (after
completion of 1
and 2)
Testing (s4); PMN (s5); PCB's (s6); Reporting (s8);
Imports/Exports (s!2/13); Asbestos; SARA Title III (8313)
FIFRA
GLP; Cancellation/Suspension; Recalls/SSURO; Establishment
Inspections; Use Investigations; Exp. Use Permit; Imports;
Reporting [including s6(a)(2>]
The following materials should be available from the
inspector's first line supervisor:
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Proqram-MinumuiB
1. FSCS/FIFRA statutues and 40 CFR regulations; TSCA
Manual; FIFRA Inspection Manual; TSCA and FIFRA
Policy Compendiums
2. FIFRA and TSCA Inspections Manuals
3. Five OECM Basic Curriculum Modules
4. Computerized Data Bases; Regional Inspection Report;
Company Files
5. TSCA and FIFRA Inspection Manuals; Inspection Forms;
Site Safety and Sampling Plans (as necessary)
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APPENDIX D-6
PUBLIC WATER SYSTEM SUPERVISION
PROGRAM SPECIFIC INSPECTOR TRAINING .
I. INTRODUCTION AND PURPOSE
The purpose of the PWSS training program is to take a
structured approach to the training of PWSS inspectors (those who
conduct or oversee compliance and enforcement activities in the
field) in order to strengthen the effectiveness of their
activities. While the program is specifically applicable to EPA
•inspectors, it may be of interest to States who conduct the vast
majority of PWSS inspections. As a national program it
establishes a core of essential training which may be
supplemented as needed.
II. DESCRIPTION OF TRAINING COMPONENTS
The purpose of a training plan is to ensure opportunity of
every inspector to acquire and refine the skills and knowledge
heeded to perform effectively. To that end, a set of experiences
should be made available, over time, inc!jding; formal course
work, self instruction and on the job training.
All inspectors for the PWSS program should be able to
conduct PWSS inspections including sanitary surveys and
enforcement case development inspections. In addition, EPA
personnel should be able to provide assistance to State
inspectors.
Basic Inspector Training and Sanitary Survey training, self-
instruction and on-the-job training are currently planned or
available for EPA inspectors. In addition, supplemental training
will also need to be developed as new requirements under the SOWA
come into effect.
III. SUGGESTED SEQUENCING
The sequence of training should be decided by the
supervisor in conjunction with the inspector after considering
the inspector's level of experience and the unique needs of the
Region. The sequencing will also be determined by the
availability of courses and the scheduling of inspections. In
general, the suggested sequence for all inspectors is as follows:
Orientation, Basic Inspector Curriculum, Sanitary Survey Course,
self study, computer based training and on-the-job experience.
For experienced inspector, training needs should be decided in
consultation with the first-line supervisor using Supervisor's
Guide to determine if exceptions for training are appropriate.
However, it may be desirable to attend the Basic Inspector
Training Curriculum and/or Sanitary Survey Course so that EPA
inspectors have a common understanding with States. Basic skills
-------
and knowledge which all inspectors will be expected to acquire,
and the associated training experiences, are detailed as
Attachment A.
IV. TRAINING MATERIALS AND THEIR SOURCES
The following kinds of materials for new inspectors should
be available from the inspector's first-line supervisor.
o General Orientation
- Organization chart
- SDWA and regulations
- PWSS Compliance Strategy
- Description of HQ/Regional/State relationships
- Applicable guidance and policy documents
o Sanitary Survey Course
- Sanitary Survey Manual (small systems)
- Training modules (large systems - to be developed)
p Program Management Training
- (to be developed)
.::'
o Skills Expansion
- (to be developed)
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Attachment A
PWSS Program-Specific Minimum and Specialized Training
SKILLS AND ASSOCIATED TRAINING
Basic Skill/Knowledge Needeed Associated Training Experience
Knowledge of EPA enforcement
philosophy and strategies
Ability to complete enforce-
ment fact gathering, with
understanding of ethics,
right of entry and inspec-
tor conduct
Understanding of health and
safety requirements
Understanding of the mission
of the PWSS Program
Understanding of the legal
authority of the PWSS pro-
gram, and enforcement
strategies
Understanding of basic public
water supply processes,
causes of non-compliance,
ways to improve operations
in large and small systems
A working knowledge of viola-
tion recognition, sampling
procedures and laboratory
analysis
A working knowledge of appli-
cable State programs and
procedures and ability to
provide constructive
oversight
Knowledge of field conditions
and procedures
o Basic Inspector Training
o Basic Inspector Training
o Health and Safety Training
o Orientation (self-study)
o Orientation (self-study)
o Sanitary Survey Course
(small systems)
Computer based training
modules (large systems)1
o OJT
o Special Courses1
o Program Management Training
(OJT/self study)1
o Sanitary Survey Course
(OJT/Self Study)
^•specialized training as needed
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APPENDIX D-7
SUMMARY OF RCRA INSPECTOR TRAINING
A. SUMMARY
The RCRA Training Program establishes the minimum
knowledge, skills and abilities necessary for those individuals
-v- carry out lead RCRA inspections, while providing flexibility
in t-aining delivery methods. The program states that courses,
supervised independent study and on-the-job training should all
be used depending on availability, resources and the needs of
the inspector. This summary describes the program for
inspectors.
The training curriculum outlined below must be completed
before the inspector conducts lead inspections (some exceptions
may be allowed based or the supervisor's judgment and only if
the actions do not jeopardize pc --ible enforcement actions or
human safety.) After the training, the supervisor will make a
determination as to whether the i-.spect \s sufficiently
prepared to perform as a lead inspector. Contact: RCRA
Enforcement Division Director, Office of dste Programs
Enforcement, Headquarters (WH-527), USEPA, 401 M Street, SW,
Washington D.C. 20460; FTS 382-4808.
The figure below shows the plan in summary.
RCRA Training Plan
_l .
I I
Coursework Supervised Independent j»lf-
Studv/OJT
(delivery method opt. na1*
1. General Orientation
2. Health and Safety
3. RCRA Regulatory Framework
(courses available)
4. RCRA Inspections RCRA Inspections OJT:
(courses available) minimum of 30 hours and
4 facility types
B. TRAINING MATERIALS
The following materials for the inspector are suggested:
1. General Orientation
- RCRA Orientation Manual
- Understanding the Small Quantity Generators (SQG)
Hazardous Waste Rules
-------
- The Resource Conservation and Recovery Act
- Videos (e.g., CERCLA's RCRA Overview)
- State developed materials covering related topics
Health and Safety
- materials to be developed
RCRA Regulatory Framework
- 40 CFR hazardous waste regulations
- RCRA statute
- HSWA statute
RCRA Inspections
- Inspection Manuals:
RCRA
State Oversight
Compliance Monitoring Evaluation
Land Disposal Restrictions
Technical Case Development
Hazardous Waste Tanks
Operations and Maintenance
Lab Audit
-1"* Effluent Guidelines
-x Equipment Manufacturer Operating Manuals
-~ 40 CFR Hazardous Waste Regulations
- SW-846
-,„ Groundwater Monitoring Technical Enforcement Guidance
- * Document
- Groundwater Monitoring Compliance Order Guide
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MEMORANDUM
SUBJECT:
FROM:
TO:
ATTU:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
CRA In^peqtor^Enhancement Strategy
L k/- ^ \L '-v^^Ls
\ Win'ston pooler
ssistant Administrator
Regional Administrators
Regional Waste Management Division Directors
In the past /ear, much attention has been given to the
importance of a quality enforcement/inspection program for RCRA.
The jRCRA Enforcement Division (RED) within the Office of Solid
Waste and Emergency Response has directed their efforts to the
enhancement of the RCRA inspection program nationwide. To.
accomplish this goal/ RED has been undertaking several major
projects. In an effort to coordinate these projects into a
manageable/ collective effort we have developed the attached RCRA
Inspector Enhancement Strategy.
With this strategy we intend to increase the quality
of inspector training/ improve the mechanisms for updating
experienced inspectors on new techniques and regulations/ and
establish a system that encourages RCRA inspectors to remain
in the enforcement area. The strategy includes the following
components:
* Training initiatives
* Inspector qualifications
* Description of inspection guidance documents
* Oversight activities
* Headquarters initiatives
* State Applicability
* Inspector Training Curriculum
A draft of this strategy was reviewed by the Regional RCRA
program offices and the Environmental Services Divisions. The
comments received were constructive and incorporated into the
strategy. The RCRA Inspector Training Curriculum (Appendix A)
was developed in coordination with the Office of Enforcement and
Compliance Monitoring and the Agency-wide Inspector Training
Policy presently in green border review.
-------
We appreciate the time that your offices have put into the
review of this strategy and look forward to its implementation
and the enhancement of the RCRA inspection program nationwide.
If you have any questions please call Elaine Stanley at
FTS 382-4808.
Attachment
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RCRA Inspector Enhancement Strategy
June 1988
Office Of Waste Programs Enforcement
RCRA Enforcement Division
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I. INTRODUCTION . -
The objectives of the strategy outlined below are to enhance
the RCRA inspection program by improving training, promoting
better recognition and opportunities for inspection personnel,
and increasing oversight of RCRA inspections; The following
areas are covered in the plan to assist in this effort:
* a description of training initiatives being
undertaken by OWPE
* a discussion of inspector qualifications
* a description of inspection guidance documents
* approaches to improving oversight of Regional
and State RCRA inspections
* additional Headquarters initiatives in the area
of RCRA inspections
* applicability to the States
Implementation of this plan will require a concerted effort
from management to emphasize the role of the ..nspector in the
RCRA program. The RCRA inspector has responsibilities which
cover the overall RCRA program and an appreciation of that fact
is needed in order to accomplish the goals set out in this plan.
The Agency has devoted extensive resources identifying and
developing solutions to problems relating to the inspection
program and investigating unique and innovative ways to improve
the program with existing State and Regional resources. These
efforts have been greatly assisted by Regional and State
participation through workgroup representation and through office
review of materials. It is essential that we maintain our
momentum by devoting adequate resources to fully meet the
objectives in this plan.
II. TRAINING
The Office of Waste Programs Enforcement (OWPE) is
currently updating guidance documents, developing inspector
training programs, and initiating new ways to transmit
information directly to the RCRA field inspector. All of
these activities should greatly enhance the transfer of
information to the inspector.
In this strategy we are establishing a minimum requirement
for inspector training. In adopting a policy of mandatory
training the concern is about the problems of getting the
training to the inspectors (or the inspectors to the training)
and using inspectors in the field who have not completed the.
required training. To address these concerns we have developed a
training requirement for RCRA inspectors which provides
flexibility to prevent resource management problems. The
training requirements are described further in Appendix A.
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We are requiring a minimum number of hours of structured
training as follows:
- General orientation 10 hours
- RCRA regulations 40 hours
- RCRA Inspection Procedures 100 hours (30 hours
must be on-the-job
training with an
experienced inspector)
It is important that the required training be structured
as detailed in Appendix A so as to provide the full benefit to
the inspector receiving the training. Meeting the training
requirement can be done in several ways including (but not
limited to) supervised independent study, classroom, and
on-the-job training. It is the responsibility of the first-line
supervisor to document how each inspector meets the required
training or, in the case of senior inspectors, how his/her
demonstrated performance justifies a waiver of the requirements.
The RCRA Enforcement Division (RED) , with input from the
Regions and States, has developed a RCRA inspector training
course. This course is designed to be given to State and
Regional RCRA inspectors and will be initially offered in the
Spring of 1988 and will be presented in all ten Regions. .The
curriculum presents current information on EPA's regulations and
policies. Training materials developed for the course (e.g.,
slides, overheads, and manuals) will be made available to the
Regions or states for in-house training. It should also provide
a stage for an exchange of information between inspectors that
has not existed on a national basis.
The Regions are strongly urged to make every attempt to make
this course available to Regional inspection personnel at all
levels. The Regions should also work with the States to
encourage state inspector attendance at this or other courses.
III. INSPECTOR QUALIFICATIONS
One of the findings of the recent GAO Inspector survey
(December, 1986-May, 1987) was that the inspection staffs at the
State and Regional level included a variety of academic
backgrounds. Some of the academic backgrounds included
biological sciences, chemistry, environmental science,
engineering, hydrogeology, ecology, and resource management.
Given that the RCRA program is one of the most complex
programs that the Agency administers and that it requires a
-------
multi-disciplinary approach, the GAO survey findings reinforces
our confidence in the overall recruiting efforts of the States
and Regions. Therefore, it is strongly recommended that State
and Regional management continue to recruit the best qualified
personnel from a broad range of academic fields.
During the Regional review process, the Regions should be
prepared to demonstrate to Headquarters their recruitment and
hiring practices to ensure that qualified personnel are being
hired to fill inspector vacancies. The Regions should also
review the states' staffing procedures to affirm that qualified
personnel are selected to perform RCRA inspections.
•IV. INSPECTION GUIDANCE DOCUMENTS.
Prior to 1987, inspection guidance documents under the RCRA
program have not been updated on a routine bc. is and have not
been adequate to meet the demands of the increasing regulatory
program. Beginning in the first quarter of FY'87, OWPE has been
developing a revised set of inspection guidance documents to
fulfill these needs. In late 1986 and early 19&7, OWPE completed
work on and published the following guidance documents:
-RCRA Ground Water Monitoring Technical Enforcement
Guidance Document
-Waste Oil Interim Enforcement Guidance
-£and Disposal Restrictions Guidance (soivents/dioxins)
-Compliance Monitoring Evaluation (CME) Guidance
3J-.
By the fourth quarter of FY'88, OWPE will have published
an entire set of new RCRA inspection guidance documents
including: .
-RCRA Inspection Manual (replaces the 1981 version)
-State Oversight Inspection Guidance
-Operation and Maintenance. Manual
-Lab Audit Manual.
-Technical Case Development Manual
-Hazardous Waste Tanks Inspection Manual
These guidance documents should replace the existing
inspection guidance documents used by the Regions-and States.
It is envisioned that these guidance documents can form the
basis for an effective Regional or State training program.
The guidance documents have been designed to be updated in
the future based on statutory, regulatory, or policy actions.
Headquarters personnel will continually review the guidance to
verify that it meets the needs of the program. In addition,
-------
Headquarters, Regional, and State personnel will determine the
need and scope for additional inspection guidance on a routine
basis.
Headquarters has developed a complete mailing list of State
and Regional RCRA inspection personnel and will mail guidance
documents directly to them. However, each Region is responsible.
for informing the RCRA Enforcement Division of any changes to the
mailing list. This mailing list will allow for the efficient
transfer of the inspection guidance documents and RCRA Inspector
Newsletter to appropriate personnel. It is also the
responsibility of the Regional office to review the State
inspection program to confirm that it is being implemented in
accordance with EPA procedures as presented in EPA guidance.
V. OVERSIGHT ACTIVITIES
One of the major findings of the GAO Survey was that there
was inadequate oversight. Oversight of inspections involves two
phases: Headquarters oversight of Regional performance and
Regional oversight of the States.
1. Regional Oversight of States
The Regions, are responsible to perform routine State
oversight inspections. The 1988 RIP did not state explicitly
that the Regions should perform 10% oversight. However, the
Regions should nonetheless strive to attain the 10% oversight.
The Regions should make a concerted effort to coordinate the
oversight inspection program with the States at the beginning
future fiscal years and to meet more frequently during the year
to meet the minimum target of 10% oversight.
Oversight inspections are one of the most important tools to
determine the effectiveness of the RCRA program. This is because
the inspector is, in many cases, the only direct link between the
owner/operator of a facility and the EPA or State environmental
agency. in order for the RCRA program to move forward, quality
inspections must be performed at RCRA sites. It is therefore
imperative that EPA verify, through the oversight inspection
program, that the inspections are thorough and complete. For
these reasons, EPA .oversight inspectors should be experienced
field personnel.
The first-line supervisor should routinely evaluate the
inspector in the field to determine overall performance and
whether the inspector requires additional training. These
field evaluations will place demands upon the supervisor, but are
needed to verify that inspectors are performing quality RCRA
inspections.
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Appendix A
RCRA Inspector Training Curriculum
ADDlicabi1it¥
This curriculum is applicable to all RCRA staff conducting field
activities. New and experienced inspectors must meet all
requirements unless the inspector can demonstrate to his/her
supervisor that he/she has had previous equivalent training or
experience that meet the requirements of this curriculum.
Delivery Methods
Delivery methods are recommended in each section, however the
ultimate decision will be determined by the supervisor and
inspector depending on availability of courses, on-the-job
training (OJT) instructors, and independent study materials.
It is recommended that two different methods of training be used
under each different section of training. This is to avoid,, for
example, any inspector being required to read for 40 hours on any
particular subject without having the opportunity to have an
alternate training experience. When possible it is recommended
that the inspectors meet the training requirements by attending
relevant courses.
--
Visual 'Aids and Training Materials
The specific materials listed in each section should be made
available to the inspector. The supervisor may choose to add
to the? specific materials listed or to use other equivalent
materials (ie. State or Regional program manuals) to meet the
objectives of each section.
Implementation and Tracking
It is suggested that the inspector complete the curriculum in the
order in which it is described. If however, when availability of
courses, materials, travel money, etc., do not allow for this, at
a minimum health and safety training must be completed before any
field work under EPA Order 1440.2. All training is required
before the inspector performs in the field as a lead inspector.*
The inspector may go into the field as a member of an inspection
team led by an experienced inspector prior to the completion of
The lead inspector is the field person responsible for
designing, conducting, and being the ultimate technical
focal point for a field evaluation of a RCRA facility.
-------
technical training. In certain cases where immediate inspection
capability is required it may be necessary to send an inspector
who has not completed the technical training. The supervisor
should carefully exercise discretion in these cases so as not to
jeopardize any possible enforcement actions or the safety of the
inspector or others. An inspector must however have some field
OJT with an experienced inspector before a solo inspection.
Level of effort (LOE) hours are assigned to each section of
training. First-line supervisors are required to ensure that the
training requirements are followed and documented. It is
recommended that the training be documented in both the training
and inspector personnel files. A training requirement checklist
(attached) including number of hours, dates and methods of
training was developed by the Office of Waste Programs
Enforcement (OWPE) to document completed training- and to identify
additional training needs.
Evaluation
Upon completion of the training requirements the supervisor will
make a determination as to whether the inspector is sufficiently
prepared to perform as a lead inspector. It is recommended that
the supervisor (or other experienced inspector) accompany the new
inspector on his first lead inspection to evaluate performance.
If the supervisor concludes that the inspector is not prepared to
carry out the duties of a lead inspector he may require
additional training of the inspector.
Continuing Education
At any time during the tenure of an inspector, the supervisor, may
require additional training for the inspector. Additional
training may take the form of an abbreviated course, self-
instruction, or OJT with the supervisor or a more senior
inspector. (This would be in addition to the Health and Safety
refresher training required under EPA Order 1440.2.)
Training for continuing education of inspectors will be developed
concurrently with new regulations and/or new and innovative
inspection procedures. Currently there are two courses for
continuing education:. RCRA Ground Water Monitoring and Land
Disposal Restrictions.
Training needs will be monitored through State oversight.
Regional reviews, and review of inspection reports. EPA
Headquarters also welcomes suggestions from inspectors,
supervisors and other enforcement personnel.
-------
Basic Inspector Training
RCRA Inspector Training is to be preceded by "Basic Inspector
Training." The Basic Inspector Training Curriculum is currently
under development by the Office of Enforcement and Compliance
Monitoring (OECM).
RCRA Inspector Orientation
Objectives: To obtain a basic knowledge of the following:
o program organization
o philosophies of the Agency/State progam
o role of enforcement (what is your job?)
o overview of RCRA and other related environmental statutes
o policies
o information sources
•V
Materials:
'„£;;
o IfCRA Orientation Manual
.I ''""
o "Understanding the SQG Hazardous Waste Rules"
EPA Publication
o The Resource conservation and Recovery Act
(as amended by HSWA)
o available videos
o state developed materials covering related topics
Methods: Supervised independent study
LOE: Minimum of 10 hours. Additional training may be required
at the discretion of the supervisor depending on the complexity
of the particular office or division.
-------
Health and Safety
o Follow requirements of EPA Order 1440.2 and OSHA
requirements (most stringent apply).
RCRA Regulatory Framework
Objective: To obtain knowledge of the RCRA regulations.
Scope:
o recent regulations
o generator requirements
o interim status requirements
o -permit requirements
Materials: 40 CFR, Resource Conservation and Recovery Act, HSWA
Methods: Supervised independent study. Some courses are
available through private firms.
LOE: 40 hours
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RCRA Inspections
Objective: Provide inspectors with the knowledge and skills to
complete an effective RCRA inspection.
Scope:
o industrial processes and associated wastes
o emergency and RCRA site-specific safety issues
o' types of RCRA inspections including elements and goals
o operation and maintenance of equipment
o cross-media concerns
o case development . .
o RCRA resources
o inspection preparation
-file review
-permit review
-EPA/State program coordination
-preparation of equipment
o sampling methods
-split samples
-packaging and shipping
o inspection procedures
-facility entry
-interaction with owner/operator
-file review
-observations
-documentat ion
.-exit interview
o inspection follow-up (reporting procedures)
-timeliness
-format
-content
Materials:
o Inspection manuals:
-RCRA
-State Oversight
-Compliance Monitoring Evaluation
-Land Disposal Restrictions
-Technical Case Development
-Hazardous Waste Tank Systems
-Operations and Maintenance
-Lab Audit
o Effluent guidelines
o equipment manufacturer operating manuals
O 40 CFR
-------
RCRA Inspections
Materials (continued):
o sw-846
o Groundwater Monitoring Technical Enforcement Guidance
Document
o Groundwater Monitoring Compliance Order Guide
Methods: OWPE has developed a JICRA inspector training course to
be available in FY 1988-89. This course will account for 32
hours of the required 100 LOE. Other courses are also available
through the Association of State and Territorial Solid Waste
Management Officials (ASTSWMO), Northeast Hazardous Waste
Project, Western Hazardous Waste Project, and.various private
firms.
LOE: 100 hours. At a minimum 30 of the total 100 hours must be
OJT inspections with experienced inspectors at four different
facilities.
Note: OJT inspection hours include all time devoted to the
inspection of the facility (eg. file reviews, on-site, report
writing, etc.).
Training for Continuing Education
Current OWPE courses:
o RCRA Ground Water Monitoring Enforcement, 24 LOE hours
o Land Disposal Restrictions, 8 LOE hours
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2. Headquarters Oversight of Regions
In future Regional reviews, Headquarters, will perform a
closer check of the oversight activities conducted by the Regions
of State inspections. This may include some Headquarters conduct
of oversight inspections in advance of the Regional review.
In addition, the Regional review team will be verifying that
there are procedures in place to provide feedback to the
inspectors. One of the reasons for inspector turnover and
frustration is that violations detected by the inspectors are not
always addressed by enforcement. The inspector needs to receive
input from enforcement personnel. on whether the information
collected and compiled in the report did not warrant any further
action or whether there were other reasons for not initiating an
enforcement action. Regions and States should have procedures in
place to provide feedback to the inspectors. The Regional review
team will ascertain whether these procedures are adequate to meet
the needs of the program.
The RCRA Enforcement Division, with the help of State and
Regional personnel, has developed a RCRA State Oversight
Inspection Guidance. The guidance stresses the fact that
oversight inspections must be well planned and coordinated
between5* the States and Regions. The guidance should be reviewed
by EPA oversight inspectors prior to conducting the inspection.
The guidance includes a discussion .of planning activities,
preparation for the inspection, conducting the inspection, and
post-inspection procedures. Findings from the oversight
inspection must be forwarded to appropriate EPA and State
personnel.
Finally, the Regions should be performing an in-depth
review of EPA oversight inspection reports and State inspection
reports. This information should be used in the mid-year and
end-of-year review process with the States in order to make
improvements to the States' hazardous waste management program.
VI. HEADQUARTERS INITIATIVES
In addition to the items discussed above, Headquarters is
developing initiatives that are designed to enhance the
inspection program on a continuing basis.. Some of these
initiatives are discussed below:
A. RCRA Inspector Newsletter
To expedite the transfer of technical and regulatory
information to the field, the RCRA Enforcement Division has
established the RCRA Inspector Newsletter. The newsletter will
-------
provide inspectors with a forum for information exchange on
various field techniques and practical application of the
hazardous waste regulations. The newsletter will be mailed
directly to State and Federal RCRA inspectors. The newsletter
should prove invaluable to field inspectors. The anticipated
benefits of the newsletter include a system that:
- Develops a national network of State and Regional
inspectors
• - Establishes a mechanism to keep inspectors abreast
of new EPA regulations
- Designates the RCRA Enforcement Division as an office
that can act as a conduit for inspector requests for
information
RCRA inspectors should be encouraged to review the
newsletters and provide input on field techniques and ideas
that may improve the procedures used by personnel in the field.
B. RCRA Training Institute
One of the proposed means of implementing the strategy is
the establishment of a RCRA Training Institute. It is envisioned
that the Institute, would perform three essential functions:
1. Conduct training courses for both entry level and
experienced personnel on a recurring basis.
2. Revise and develop the curriculum for the courses
with input from Headquarters and the Regions.
3. Participate in actual field inspections for the
purpose of relating that experience to students.
. OWPE would be responsible for revising the curriculum to
include new regulations and policies and for providing
instructors to teach the course. Training institute personnel
would be responsible for the actual course presentations and for
participating in field investigations to stay abreast of field
techniques and practices.
C. Classification Guidance
The RCRA Enforcement Division is investigating the
promotion of non-supervisory RCRA enforcement staff, including
inspectors and compliance officers, to the GS-13 level. Guidance
on this subject was transmitted to the Regions in the form of a
memorandum (dated 12/15/86) from Jack McGraw to the Regional
-------
Waste Management Division Directors. The guidance also presents
procedures for the promotion of nori-supervisory personnel to the
GS-14 and GS-15 levels. The Regions should pursue this
initiative to support qualified personnel for higher grade levels
in the RCRA enforcement program.
Another approach involves establishing a classification
system which enables inspectors with exceptional abilities
and performance to receive greater recognition. The system
would recognize different levels of experience and expertise
.and could include the following job titles:
-Inspector
-Senior Inspector
-Civil Investigator
This approach may enable the Agency to retain senior personnel by
providing a goal for inspectors that involves increased
responsibility and recognition.
D. Agency-Wide Inspector Training
The Office of Enforcement and Compliance Monitoring (OECM)
has the lead in developing an Agency-Wide Inspector Training
Strategy-. The strategy is investigating various options for
inspectors under all programs within EPA and includes a
requirement for mandatory and systematic basic training. This
basic training requirement would apply to all programs. The
Regions would adopt the basic training requirement into the
inspection program after the policy was finalized by
Headquarters.
E. State Applicability
It is the Agency's intent that we encourage the States to
adopt this strategy and comply with the requirements specified
within. In some cases, the States may have similar .programs in
place which address the requirements for training and
recruitment. The Regions should discuss training programs with
State management during the review process to determine
comparability with the items mentioned in this strategy.
As mentioned previously, the Regions should encourage the
States to attend the training course being developed by the RED
and the States should adopt and revise the training for their
in-house training programs.
-------
Regional/Sta
Date of Hire:
Area of Trainii
(r*quir*d hourt)
H.alth and Saf.ly
(40hn>
Satie
(40 hr»)
SCRA Oritntatien
(lOhrt)
SCSI R«st.
(40 hn)
5C«A Int p«c'.ior.t
C.CO hn)
Continuing Ed.
Continuing Ed.
Signature/ In
Signature/ SL
te Office:
ig
Sup*rvit*d
lnd*p*nd*nl Study
•hrt:
Oat*:
Plae*:
•hrt:
-Calt:
Place
D,!.:
rllct:
Traini
On-tho-jeb
•hrt
Oat*
Plae*
•hrt
Oat*
Plae*
•hrt:
Da!*:
Piaet:
Cat*: _. : ,-.f.-
Plae*:
Cat*:
rlae*:
•hrt:
Oat*:
-. PJae*:
•hrt:
Dal»:
Plae*:
Plic.-
•hrt:
rate-
Pile*:
•hrt:
3at*:
Plae*:
• hrt:
Pf»e*-.
specter:
ipervisor-
Court*
(Include nam*)
Other
Total
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