UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OSWER Directive 9842.2
AP£ 3 133-1
. V ^ -> , -J-J ' OFFICE OF
SOLID WASTE AND EME3GE\C'
MEMORANDUM
SUBJECT: CERCLA Implementation of Inspector Training Requirements
for OSCs/RPMs at the Intermediate Level in STEP and
First-line Supervisors
FROM: Bruce M. Diamond, Director^ppP^ /
Office of Waste Programs Enforcement a
Timothy Fields, Jr., Acting Director~d£f*
Office of Emergency and Remedial Response
TO: Waste Management Division Directors
Regions I - X
Environmental Services Division Directors
Regions I - X
I. PURPOSE
The purpose of this memorandum is to provide guidance on how
two groups of CERCLA staff can meet or be excepted from the
training requirements of EPA Order 3500.1 on Inspector Training.
These two groups are: 1) OSCs/RPMs who were grandfathered into the
Structured Training and Evaluation Program (STEP) at the
Intermediate level and 2) First-line supervisors of OSCs/RPMs.
Previous guidances addressed the other groups of CERCLA staff to
whom the Order applied.
II. BACKGROUND
EPA Order 3500.1, Training and Development for Compliance
Inspectors/Field Investigators (June 29, 1988), established a Basic
Curriculum and requirements for the development of Program-Specific
Minimum Curriculum for Inspectors before they lead or conduct
inspections independently. 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 Order also applies to.the first-
line supervisors of those staff who meet the Order's definition of
an Inspector.
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In November 1988, OSWER issued guidance (OSWER Directive
9842.0) on the applicability of the Order to CERCLA staff in the
Regions and provided a definition for determining the CERCLA staff
who are subject to the Order's requirements.
Additional guidance was provided in October 1989 (OSWER
Directive 9842.1) on CERCLA's implementation of the Order's
training requirements for most On-Scene Coordinators (OSCs) and
Remedial Project Managers (RPMs) . It was stated in that memorandum
that guidance on the one group of OSCs/RPMs for which a policy had
not been formulated and first-line supervisors of OSCs/RPMs would
be forthcoming.
III. TRAINING REQUIREMENTS FOR INTERMEDIATE OSCs/RPMs
CERCLA tied fulfillment of the Order's requirements into its
own program-specific initiative, the OSC/RPM Support Program. One
component of this program is the Structured Training and Evaluation
Program (STEP). STEP established four levels of experience,
knowledge and skills required to manage progressively more complex
Superfund sites/incidents. These levels are: (1) Basic, (2)
Intermediate, (3) Advanced, and (4) Master. As stated in OSWER
Directive 9842.1, OSCs and RPMS grandfathered into STEP at the
Advanced and Master level were formally excepted from the
requirements of the Order, and staff at the Basic level would have
completed the OSC/RPM Basic Training Academy which fulfills the
Order's training requirements. It is the remaining group of
OSCs/RPMs grandfathered in at the Intermediate level which will be
addressed by this guidance.
Staff grandfathered in at the Intermediate level had to
demonstrate training and experience in specific CERCLA areas in
order to attain Intermediate status. However, these training and
experience requirements did not meet all of the legal fundamentals
training requirements in EPA Order 3500.1. Therefore, the OSC/RPM
staff designated at the Intermediate level should attend one of the
following three courses which have been identified as meeting the
legal fundamentals requirements in the Order. They are: (l)
"Fundamentals of Environmental Compliance Inspections", or (2)
"Introduction to Superfund Enforcement" (or Region I's equivalent,
"Enforcement and Remedial Activities Under CERCLA"), or the
Superfund University Training Institute's "Legal Issues" course.
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IV. TRAINING REQUIREMENTS FOR FIRST-LINE SUPERVISORS
The Order provides that experienced first-line supervisors
and experienced OSCs/RPMs who were appointed to positions as First-
line supervisors after June 29, 1988, when the Order was signed,
may be formally excepted from the requirements in the Order.
However, new first-line supervisors of OSCs/RPMs are required to
meet the training requirements within one year of appointment to
the supervisory position.
CERCLA is recommending that new first-line supervisors of
OSCs/RPMs attend one of the three courses identified below in order
to satisfy the Order's requirements. They are: (1) "Fundamentals
of Environmental Compliance Inspections" or, (2) "Fundamentals of
Environmental Compliance Inspections for Supervisors" or, (3)
"Introduction to Superfund Enforcement".
V. CONTACTS
For additional information on this guidance or the training
courses identified in this guidance, please contact Debby Thomas in
OWPE at FTS 398-8656. A summary of the exceptions and training
courses for all OSCs/RPMs and for first-line supervisors is
provided as an attachment.
Attachment
cc: Elaine Stanley, OWPE (OS-500)
Sally Mansbach, OWPE (OS-510)
Margaret Kelly, TIO (OS-110)
Marlene Suit, TIO (OS-110)
Becky Barclay, OE (LE-133)
Inspector Training Advisory Board
OSWER Regional Training Contacts
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SUMMARY OF GUIDANCE FOR CERCLA STAFF MEETING OR BEING EXCEPTED FROM
THE REQUIREMENTS OF EPA ORDER 3500.1
STAFF
New OSCs/RPMs
TIMEFRAME FOR
MEETING
REQUIREMENTS
Beginning 10/1/89,
any new OSC/RPM
hired
TRAINING OR
EXCEPTION POLICY
Must attend OSC/RPM
Basic Training
Academy
Experienced
OSCs/RPMs who have
attained the
ADVANCED or MASTER
level via the
Structured Training
and Evaluation
Program (STEP)
By 10/1/91
EXCEPTED from
requirements
Experienced
OSCs/RPMs who have
attained
INTERMEDIATE level
via STEP
By 10/1/91
Must complete 1 of
the following 3
courses:
"Fundamentals of
Environmental
Compliance
Inspections"
developed by OE
OR
"Introduction to
Superfund
Enforcement"
developed by OWPE
(or Region I's
equivalent,
"Enforcement and
Remedial Activities
Under CERCLA"
OR
"Legal Issues", a
Superfund
University Training
Institute (SUTI)
course.
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New first line
supervisors of
OSCs/RPMs who have
not previously been
OSCs/RPMs
themselves
Beginning 10/1/89,
within 1 year of
assuming
supervisory
position
Must complete 1 of
the following 3
courses:
"Fundamentals of
Environmental
Compliance
Inspection"
OR
"Fundamentals of
Environmental
Compliance
Inspections for
Supervisors"
OR
"Introduction to
Superfund
Enforcement"
Experienced 1st
line supervisors
(including those
who had been
experienced
OSCs/RPMs and were
then appointed to
positions as 1st
line supervisors
after 6/29/88)
By 10/1/91
EXCEPTED from
Requirements
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