The Utah Stormwater Advisory Committee, made up of the Utah Department of Environmental Quality and municipalities throughout the state, meets each month to discuss stormwater issues.
For members of the Utah Stormwater Coalition, it’s important to keep up with the issues that the State and the MS4s are discussing, so we’ll be sending out a newsletter each month following the USWAC meeting to let you know what was talked about.
In September, the focus of the USWAC meeting was training. Obviously, this focused on the training required by the municipalities, but some of the topics are relevant to us.
Public Education and Outreach
The MS4s, in their stormwater permit, are required to provide education and outreach annually to various groups, including to Institutions, Industrial, and Commercial Facilities (4.2.1.3 of the Utah Small MS4 Permit) and to engineers, construction contractors, developers, development review staff, and land use planners (4.2.1.4).
While we don’t have to attend these training events, the MS4s do have to provide them. Currently, many MS4s in the State don’t offer much, if anything, in the way of complying with this requirement. What is good to keep in mind, however, is that it’s the City’s responsibility to keep you informed of their requirements. If they haven’t offered you any training or outreach opportunities to keep you informed, you can use that if and when there are any issues at your sites or facilities.
Training Requirements Under CGP and MSGP
It’s also important to note that, while the MS4s are required to provide training, any of us who are currently covered under the Construction General Permit or the Industrial Multi-Sector General Permit also have training requirements we are obligated to fulfill.
CGP
Section 6 of the Construction General Permit lays out the Staff Training Requirements for anyone with an open NOI (Notice of Intent) and coverage under the permit.
Each site must have a “stormwater team” that is ultimately responsible for stormwater compliance.
Each of the following personnel must understand the permit requirements and their specific responsibilities:
BMP installers and maintainers
Inspectors
Personnel conducting corrective actions
Personnel responsible for the application or storage of treatment chemicals
Subcontractors whose work may affect any requirements of the permit
No formal training program is required.
MSGP
The MSGP goes one step further and requires training on the SWPPP at least annually for all personnel that work in areas where pollution may occur or where chemicals are used or stored.
This annual training has to be described in the SWPPP and you must keep a record of it.
As a member of the Utah Stormwater Coalition, you have access to free training materials for you and your company. Call or email us to find out more.
If you have any questions about your specific requirements or are concerned that a municipality is promoting excess requirements without providing training, please contact us.
385-483-7001
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