&EPA
UnmM Suttt
Environmental Protection
Solid WMI» end
Emergency R«»con««
DIRECTIVE NUMBER: 9842.1
TITLE: CERCLA Implementation of the Training
Requirements of EPA Order 3500.1- Inspector Training
APPROVAL DATE: Oct. 19, 1989
EFFECTIVE DATE:
ORIGINATING OFFICE: Office of Waste Programs
Enforcement
H FINAL
D DRAFT
STATUS:
REFERENCE (other document*):
EPA Order 3500.1
OSWER Directive 9295.9-05
OSWER Directive 9842.0
[ ] A- Pending OMB approval
[ ] B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- In development or circulating
headquarters
Ti'M
DIRECTIVE DIRECTIVE L
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unnea oiaies environmental rrotection Agency
Washington. DC 20460
OSWER Directive Initiation Request
2. Originator Information
Name of Contact Person
Debby Thomas
Mail Code
OS-510
Office
OWPE/Comp Br
1. Directive Number
9842.1
••^^^•M^^M
^-^^—~^~^^«aft Level
A - Signed by AA/DAA
8 •- Signed by Office Director
C - For Review & Comment
rn D - in a
In Development
8. Document to be distributed to States by Headquarters?
— —
Yes
F
No
This Request Meets OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
10. Name and Title of Approving Official
Date
Date
EPA Form 1315-17 (Rev. S-87) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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MiTEO 3 PATES ENVIRONMENTAL PROTECTION AGENCV
WASHINGTON. O.C. 20460
OCT I 91989
OSWER Directive 9842.1
MEMORANDUM
SUBJECT:
FROM:
TO:
CERCLA Implementation of the Training R«
Order 3500.1 - Inspector Training
Henry L. Longest II, Director
Office of Emergency and Remedial
irements of EPA
Jruce Diamond, Director
Office of Waste Programs Enforcement
Waste Management Division Directors
Regions I - X
Environmental Services Division Directors
Regions I - X
I. PURPOSE
The purpose of this memorandum is to explain how On-Scene
Coordinators (OSCs) and Remedial Project Managers (RPMs) may
satisfy the requirements for Inspector Training under EPA Order
3500.1, or may be granted an exemption from those requirements.
An exemption may be granted depending on the implementation of the
Structured Training and Evaluation Program (STEP) . STEP is a key
component of the OSC/RPM Support Program created by OSWER.
Depending on the various levels in STEP - Basic, Intermediate,
Advanced or Master - to which an OSC/RPM is assigned, an exemption
may be granted from the training requirements of the Order.
ii.
EPA Order 3500.1, Training and Development for Compliance
Inspectors/Field Investigators (June 29, 1988) , established a Basic
Curriculum and requirements for development of Program-Specific
Curricula for Inspectors. This Order applies to all EPA personnel
who lead or oversee the conduct of compliance inspections/ field
investigations on a full or part-time basis under any of EPA's
statutes, including CERCLA. The requirements in the Order also
apply to the first-line supervisors of staff who meet the Order's
definition of an Inspector. A copy of Order 3500.1 is included as
Attachment A.
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III. APPLICABILITY OF ORDER TO CERCLA STAFF
In November 1983, OSWER issued guidance on the applicability
of the Order to CERCLA staff (Attachment B) in the Regions. This
guidance provided a definition for determining the CERCLA staff
who are subject to the Order's requirements. This definition
included, at a minimum, OSCs and RPMs involved in field activities
and their first-line supervisors.
IV. IMPLEMENTATION OF THE ORDER'S TRAINING REQUIREMENTS
EPA Order 3500.1 established important requirements for basic
and program-specific minimum training to be completed before an
Inspector could lead an inspection. The Order also reiterated
existing requirements for health and safety training. To satisfy
the requirement for basic training, OECM developed a course,
"Fundamentals of Environmental Compliance Inspections" for all
inspectors regardless of the program area, to be implemented by the
Regions across the entire organization. Program Offices are
responsible for developing and delivering the program-specific
curriculum.
CERCLA, however, has tied fullfillment of the Order's
requirements into its own program-specific initiative, the OSC/RPM
Support Program. Two components of this Pr:gram, (1) the seven-
week OSC/RPM Basic Training Academy and, (2) the Structured
Training and Evaluation Program (STEP) are directly linked to the
requirements for training and granting excep ions as stated in the
Inspector Training Order. The first session of the OSC/RPM Basic
Training Academy began in May 1989, and the second is scheduled to
begin in late October 1989. All staff who complete the Academy
will satisfy the requirements of EPA Order 3500.1.
V. STEP AND EXEMPTIONS
Decisions made on STEP will affect how CERCLA personnel are
handled under EPA Order 3500.1. STEP establishes, four levels of
experience, knowledge and skills required to manage progressively
complex Superfund sites/incidents. These levels are: (1) Basic,
(2) Intermediate, (3) Advanced, and (4) Master. Decisions on
training requirements and exceptions are tied to these levels.
The evaluation process for all OSCs/RPMs is not complete at
this time, but is scheduled to begin this Fall. Once this
evaluation has been completed, the exceptions policy defined for
each level will apply as stated in the SUMMARY section of this
memorandum.
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The OSC/RPM staff designated at the Master or Advanced Level
will generally be excepted since they will have satisfied the
requirements of the Order. Based on nominations and review this
past Spring, 48 OSCs/RPMs have been designated as Masters.
We have not yet established a policy for those OSCs/RFMs
designated at the Intermediate Level, or below who did not attend
the Academy, nor for first-line supervisors of OSCs/RPMs. This
will be finalized in the Fall of 1989, as the evaluation process
is established. These CERCLA staff should keep in mind that
attendance at a Regional offering of the "Fundamentals of
Environmental Compliance Inspections" course satisfies the basic
curriculum in the Order and is a viable means of partially
completing the training requirements. However, the program-
specific curriculum requirements in the Order would still need to
be satisfied or excepted. These decisions will be made during the
grandfathering process.
New OSCs/RPMs who have attended or who are required to attend
the Superfund OSC/RPM Basic Training Academy will satisfy the
requirements of EPA Order 3500.1 by completing all sessions of the
Academy. OSWER Directive 9295.9-05, "Mandatory Training
Requirements for OSCs and RPMs" (Sept. 29, 1989), specifies who
must attend the Academy.
VI. SUMMARY
Attendance of new OSCs/RPMs at the OSC/RPM Basic Training
Academy will satisfy the requirements of Order 3500.1. There are
no exceptions to this policy for new OSC/RPM Superfund staff.
Staff who will be grandfathered into the STEP program at the
Advanced and Master levels are formally exempted from .the
requirements of the Order. OSCs/RPMs grandfathered in at the
Intermediate Level may need additional training or may be exempted
from EPA Order 3500.1 based on previous training and/or experience.
These decisions will be made in conjunction with the grandfathering
process in the Fall of 1989.
First-line supervisors are not included in the STEP program.
Therefore, training options and guidance on exceptions still needs
to be developed for this group. We aim to have this guidance
prepared by February 1990.
Further guidance in the form of a memo will be provided in the
near future on tracking and compliance procedures for STEP.
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If there are questions, or if additional information is needed
regarding CERCLA's implementation of the requirements of EPA Order
3500.1, please contact Debby Thomas at FTS 475-7028.
Attachments
cc: Bruce Diamond
Henry Longest
Colleen Carruthers
Advisory Board (Inspector Training)
Training Contacts
Meg Kelly
Becky Barclay
Marlene Suit
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]fl|Classification No.: 33QC.1
w Approval Data: Jln» 29,
TRAINING AND DEVELOPMENT FOR COMPLIANCE INSPECTORS/PIELD INVESTIGATORS
1. PURPOSE. This Order establishes a consistent Agency-wide training and develop-
ment program for employees leading environmental compliance inspections/field
investigations.
2. APPLICABILITY. This order applies to all Environmental Protection Agency (EPA)
personnel who lead or oversee the conduct of compliance inspections/field
investigations on a full- or part-time basis .under any of EPA's statute*.
This order is advisory to state and local agencies.
3. POLICY. It is the policy of the Environmental protection Agency to ensure.
that those who lead environmental compliance inspections/field investigations are
properly trained to perform these functions in a legally and technically sound
manner.
4. RrrmENCES. ^
a. EPA 1440. Occupational Health and Safety Manual: Chapter 1, Occupational
Health and Safety Training.
b. EPA Order 1440.2, Health and Safety Requirements for Employees Engaged in
field Activities.
c. EPA Order 1440.3, Respiratory Protection.
d. Agency-wide Program to Train, Develop and Recognize compliance inspectors/
Field Investigators: A Program Description, June, 1988.
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
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JCC.l
compliance status of facilities or sites with applicable laws, standards, reaulat:<
and permits and/or of supporting appropriate enforcement action (administrative,
civil judicial or criminal), including:
(1) planning and carrying out inspections of collation
relevant facility operations and .-naintenance practices, self-monitor xr.c 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 c.-.e
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 or
program 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 CQtCLA 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 froa other programmatic responsibilities*
r
b. New Compliance Inspector/Field Investigators. Including:
(1) Individuals newly employed by EPA subsequent to the issuance date
of this Order regardless of previous training in anc experience leading environ-
mental 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 pcooraM.
d. First-line Supervisors of inspectors. A first-line supervisor is the
immediate supervisor of the day-to-day work of an individual 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 S(c).
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e. Contract inspectors and ethers. This category includes contract
personnel and employees of a grantee organization under the Senior -r.vircrrer.tal
Employment Program, performing compliance inspect ions/field invest! rations ..-.dec
SPA'S statutes.
f. Leading an Inspection. Leading an inspection r.eans i.-.deper.der.zly
conducting a compliance inspection/field investigation or directl.-.g 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.
(3) Classroom/classes. This refers broadly to any fora of instruction,
flexible in format and size/ to include seminars, workshop*, lecture-type or
video-assisted classes, or question-and-answer session* following prior '
independent self-study, that fosters group interaction with an instructor dc an
experienced inspector.
h. Completing Required Training. Completion of required training means
completing self-study, OJT and participation in classes covering the oentent
described in applicable training curricula.
6. TRAINING PROGRAM. EPA's training program consists of three parts — occupa-
tional Health and Safety Curriculum, Basic curriculum, and Program-specific
Curricula — as follows.
a. occupational Health and safety curriculum. EPA Order 1440.2 establishes
basic, intermediate, advanced and refresher requirements for occupational
health and safety training for all EPA employees before engaging in any field
activities. In addition, EPA compliance inspectors/field investigators must
meet requirements, where these apply, of EPA order 1440.3 for Respiratory
Protection. A summary of the curriculum is found in Appendix B of Reference
4(d) above, contractor personnel must meet training requirements of applicable
regulations of the Occupational safety and Health Administration (OSHA).
b. Basic Inspector curriculum. This curriculum establishes required
training to provide a comprehensive overview of knowledge 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. It also includes the occupational Health and Safety
Curriculum cited in 6(a) above. Th« Basic Curriculum is summarized in Appendix c
of Reference 4(d) above. Related supplemental Training is recommended to further
develop some of these skills, as summarized in Appendix f of Reference 4(d) above.
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250C.2
£PA ORDER
c. Program-Specific Curricula. The Program-Specif ic Minimum Curricui j.
for each ma]or environmental program establishes required training in Legal,
programmatic and technical subjects. Any EPA conpliance inspector conduct-..-:
inspections in rare than one program is required to have completed trie r2_-=va.-.t
Program-Specific Minuiun --.irricula in each such program. Program-Spec if-.c
Specialized Training is recommended to further develop inspection skills.
Stannaries of these curricula are availaole in Appendix D, of Reference 4(d) aocve.
A summary of multi-media (multi-program)traimng" reconnendations is availaole ;n
Appendix E of Reference 4(d) aoove.
d. Refresher Training.
(1) Occupational Health and Safety: EPA Orders 1440,2 and 1440. 3
require refresher training annually.
(2) Basic and Program-Specific Minimum Curricula; Refresher training in
both the Basic Curriculum and Program-Specific Minunura Curricula is strongly
nded, but at the discretion of the first-line supervisor. At a minimal,
refresher training should occur every three years, or more frequently, depending
on the needs of the individual/ and changing emphases or needa in the compliance
and enforcement program.
7. Re^UlkOElIS AND EXCEPTIONS. >
a. Before Any Field Activities. All coapliance inspectors and first-line
supervisors of inspectors are required to oooplete applicable occupational
health and safety training before any field activities as defined in EPA Order*
1440.2 and 1440.3. f
b. Before Leading Inspection/Investigations. All conpliance inspectors/
field investigators must complete the Basic Curriculjn and the Program-Specific
Minimum Curriculum in the assigned program area(s) before leading an inspection.
experienced inspectors may be excepted from the Basic Curriculum, but new
inspectors may not. There may be limited exceptions to program-specific require-
ments for new and experienced inspectors.
c. Within One Year vftien Supervising. The requirements to complete the
Basic and Program-Specif ic Minimum curricula apply to first-line supervisors
of conpliance inspectors. First-line supervisors shall meet these requirements
within one year of appointment to the supervisory position, if they have not
already done so. If the first-line supervisor directs inspectors/investigators
in two or race programs, the supervisor may need additional time to complete all
of the applicable Program-Specific Minima Curricula, and should do so as soon
as practicable* Experienced first-line supervisors may be excepted from the
Basic Curriculum but net ones may not. There may be limited exceptions to
program-specific requirements for new and experienced first-line supervisors.
d. Procedures) for Exceptions.
(1) Health and Safety Training. Any exceptions to the occupational
health and safety training requirements mu»t be in accordance with Paragraph
9(d), EPA Order 1440.2, or the provision* o£ 1440.3.
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•5/2S-/58
(2) Basic and Program-Specific Mir.i.-rmn Curricula. In the Regions,
exceptions .-rust be approved by the Regional Administrator. Delegation aelcw
this level may be jade to the Deputy Regional Administrator or a cross-r«g:c.-.3l
panel of ;tanagers established for this purpose, out excludi.-.g tr.e _-7r.ec~.I-e
first- or second-line supervisor of the individual for whom the exception ;s ze;-~
requested. For Program Offices with ihspectors 'oased in Headquarters, tr.e
Assistant Administrator shall approve exceptions for those inspectors, ^eiegaticr.
below this level ray be rnade to the Deputy Assistant Administrator, or Office
Director, or in the case of OECM, to the Director of the National Enforcenent
Investigations Center (NEIC). The first-line supervisor shall prepare a -written
request based upon guides for evaluating the previous knowledge, experience
and/or training of the inspector, and shall submit this to the approving official,
according to procedures adopted in the Region or Headquarters, whichever apply.
A copy of the approved written request shall be placed in the employee's official
personnel file along with other training records.
8. £fF&JPIVE DATE*
a. Occupational Health and Safety Training* The requirements of EPA
Orders 1440.2 and 1440.3 are in effect and will remain in effect.
b. Basic and Program-Specific Minimum Curricula* This Order is effective
on the date of issuance; however/ requirements are phased in as follows* t
(1) New Inspectors. 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 Pi umlaut-Specific Minimus
Curricula.
r
(2) Experienced Inspectors. Beginning Octooer 1, 1991, experienced
inspectors shall not lead inspections unless they have completed or have been
formally excepted from the Basic and Program-Specif i- Minimum Curricula.
(3) First-line Supervisors. Beginning October 1, 1989, all first-line
supervisors shall meet the requiranents of this Order or have been formally
excepted within one year of appointment to the supervisory position, or as
scon as practicable, for those with two or more pcogiaas.
(4) Contract Inspectors and Others. Training requirements for EPA
contract inspectors snail be appropriately phased into future contracts or
solicitations involving compliance inspection work. These requirements shall
be incorporated into future assistance agreements awarded under the Senior
Environmental Employment Program involving compliance inspections.
. RESPONSIBmna* This section lists the primary responsibilities for
mplementing uus order. ;
detailed list of responsib'
implementing tms order. Appendix G of Reference 4(d) above contains a more
(illties.
a. Assistant Administrator for Enforcement and Compliance Monitoring (OBCM
The Assistant Administrator for Enforcement and Compliance Monitoring is
responsible for:
(1) U|pdating this Order, and overseeing and evaluating iaplaaentation
of the; overall program requirements every 3 years?
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(2) Developing, updating and disseminating student .Ttanuals and
instructor's guides for the 3asic curriculum to the Regions, coordinating the
selection of and rnaintaining a list of instructors from the Regions and Head-
quarters; and
(3) Orcanizirsc a board of Senior Agency Managers frcm Headquarters
and Regions, and inspectors/investigators co advise him/her in carrying GU=
the responsibilities listed above.
b. Assistant Administrator for Administration and Resources Management.
The Assistant Administrator for Administration and Resources Management is
responsible for:
(1) updating and providing sufficient materials for occupational
health and safety training, or approving non-EPA courses to meet the requirements
of EPA orders 1440.2 and 1440.3, and reviewing program-specific health and safety
training.
(2) Training and evaluating EPA personnel designated as instructors
for delivering the Inspector Health and Safety curriculum; and
(3) Coordinating and disseminating a timely schedule of classes
of the Health and Safety, Basic, and Program-Specific curricula, in consultation
with OECM, Program offices and the Regions.
c. Assistant Administrators. The Assistant Administrators are responsible
for:
(1) implementing the requirements of this Order and Agency prqgram
[Reference 4(d)] within their areas of jurisdiction, including periodically
evaluating implementation;
(2) Developing, updating, and disseminatinc materials and schedules
for classes under the Program-specific Curricula, in consultation with Regions
and states, and providing a plan by October 30, 1988, for implementing the Basic
curriculum for inspectors based in Headquarters;
(3) Establishing guides for first-line supervisors of inspectors
to evaluate the training and development needs of compliance inspectors/field
investigators and approving requests for exceptions}
(4) Determining who among those inspectors/investigators based in
Headquarters are subject to this Order, and reviewing and approving exceptions
to the training requirements requested for these personnel.
(5) Btsuring in future contracts and assistance agreements awarded
under the Senior Bivironmental Employment Program involving compliance inspections
that training is required by means of statements of work or other appropriate
vehicles; and
(6) 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.
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EPA ORDER
c/29/68
d. Regional Administrators. The Regional AdTiinistrators are responsible
far:
(1) Implementing the requirements of inis Order and Agency program
[Reference 4(d)J within their areas of jurisdiction, including periodically
evaluating implementation;
(2) Determining who in the Region is subject to this Order, and reviewing
and approving any exceptions to the training requirements;
(3) Ensuring in future contracts involving compliance inspections that
training is required by means of statements of work or other appropriate vehicles;
», (4) Supporting in-house instruction for the Basic Curriculum, by
working with OECM to identify Regional personnel to serve as classroom instructors
and providing a Regional implementation plan by October 30, 1988; and
(5) Ensuring each program identifies States* inspector training needs
annually through the State/EPA Enforcement Agreements process) assisting States
in identifying ways to meet their training needs; and coordinating training oppor-
tunities.
e. Line Supervisors. Line supervisors in Ptuutam or Environmental
Service Divisions, are responsible for:
(1) Ensuring quality compliance inspections/field investigations using
performance standards* periodic appraisals, appropriate assignments to ensure
development, and recognition of personnel engaged in the compliance
monitoring function; and
*
(2) Identifying employees who require training, ensuring that employees
comply with the requirements of this Order, preparing requests for exceptions,
and maintaining records of actions.
, k
f. Compliance Inspectors/Field Investigators. Compliance inspectors/
field investigators are responsible for:
(1) Advising their supervisor about the history and extent of relevant
training and experience, and assisting in the preparation of an Individual Develop-
ment Plan to meet the requirements of this Order; and
(2) Replying and maintaining the knowledge, skills, and techniques
acquired through training to ensure that inspections/investigations are
accomplished in a technically and legally sound manner.
A* Janes Barnes
Deputy Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20440
' CV 2 3 988
SOUO wA*r| 4*0
MPfQRAflOUM
SUBJECT: Guidance on Applicability of EPA Ordtr 3500.1 to C£RCIA
Staff
FROM: Bruca N. Oiaaond, Oiracto
Office of va«t« Program* £n
Honry L. Longest II, Director
Office of Emergency and R«Mdia
TO: tfaat* Managamant Oiviaion Director*
Regions I - X
Environmental Services Division Directors
Regions I - X r
On June 29, 19ta, EPA Order 3500.1 established training
requirements for Compliance Inspectors/Field Investigators. This
order applies to all EPA personnel who i«ad or oversee the
conduct of. compliance inspection/field investigations on a full
or part-time basis under any of IPA's statutes, including CEHCLA.
However, since CERCLA staff do not perform classic
compliance inspections, the order allovs the CZRCLA program
offices to define), through guidance to the Regional
Administrators), wfeich C2XCLA staff shall be subject to the
Order's resjuiramMntau It also indicates that a CERCLA-specifie
curriculsn im beino; developed to address the required training.
Th* 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 (PR*) projects for the
purpose of ensuring PRP compliance or for obtaining evidence to
use in potential enforcement actions.*
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definition should include, at a niniaua, On-scene
(OSCs) and Remedial Project Managers (RPMs) involved
in fieie>»*etivities. However, it is understood, per section
9d(2) of the Order, that the Regional Administrator aaXes 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.
In addition to the health and safety training currently
required, the Order mandates a minimum of forty hours that
cover:
o L*a«i fundamental* - introduction to enforcement of EPA
statutes, overview of enforcement and compliance goels
and strategies, administrative and judicial litigation
processes, legal authority and EPA policies regarding
gaining entry, uee of information-gather! .< tools, and
defining and documenting evidence).
o r*eimie*i iseuee - rolee and responsibilities of aw
inspector/investigator, violation detection and
inveetigative techniques, records inspection,
statistical sampling strategies, obtaining physical
samples, QA/QC, and lab analysis
o fiQBa\inlt=**iQn skills - notification, negotiation
techniques, elements of an inspection plan, written
documentation e reporting requirements
o Administrative - planning considerations, travel,
records management, organizational structure, contract
mechanisms
To meet these requirements, our offices will slightly
modify the •O8C/KVN Basic Course". Additionally, the OSC/RPM
Support Prograsj developed by OERft calls for an osc/RPM Academy to
be pilots* la April 1999 which will provide 41 days of required
trainings* new OJCs and RPMs that will also meet, as part of
its curifclM, the) training requirements in EPA Order 3500.1.
At tfcls) tiat), 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 CEHCLA staff or the curriculum,
pleass feel frss to contact either of us.
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ATTSCiSiT C
Phaainq-1n
Sections 8.b.(l), (2), and (3) distinguish between new
inspectors/ experienced inspectors and "all" first-line super-
visors, as follows.
Kev Inspectors! "Beginning October 1, 1989, 'new* inspec-
tors shall not lead inspections unless they have coapleted the
Basic Curriculum, and have coapleted, or have been formally ex-
cept ed, froa the Program-specific Miniaua curricula."2
Experienced Inspectors: "Beginning October 1, 1991,
•experienced* shall not lead inspections unless they have
completed or have been formally excepted froa the Basic and
Program-Specific Minimum Curriqula."
First-Line Supervisors; "Beginning October 1, 1989, all
first-line supervisors shall meet the requirements of this Order
or have been formally excepted, within one year of appointment to
the supervisory position, or as soon as practicable, for those
with two or more programs."
The Deadline for Experienced First-Line supervisors is
October 1. 199Q. This interpretation reflects the general
approach of the Order, to phase in requirements for experienced
personnel over a slightly longer time frame.
The Order Allows More Time for Supervisors Who are
Responsible for Two or More Programs.
Supervisors directing inspectors in two or more areas may
do the following: coaplete the "Fundamentals" course and one
program's minimum curriculum within one year, and coaplete at
least one additional program curricula each year thereafter until
the supervisor has coapleted them all. This is the maximum
amount of tia* allowed. If the supervisor can coaplete the
required training more quickly than this, s/he should do so.
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