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Excerpt from "SPCC training requirements"
You’ve developed and implemented a Spill Prevention, Control, and Countermeasure (SPCC) Plan that meets all federal SPCC regulatory requirements. You’ve put into action an inspection program that is well documented in your Plan, and you’ve made sure that all secondary containment is sufficient to prevent an oil discharge to navigable waters and adjoining shorelines. It sounds like your facility is fully compliant with the SPCC regulations, right? But unless you have implemented a training program and are routinely training oil-handling personnel, you could be subject to enforcement. This paper explains how to develop and implement a compliant SPCC training program.

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