Stormwater Program for Industrial Activity: Steps to Compliance

Step 8: Install BMPs, train employees

Installing BMPs

Assess which BMPs you selected before you begin implementing them.  Ask yourself these questions:

• Which ones are the easiest to implement, or take the least amount of time to install?
• Which ones will require the most time/money?
• Which ones will have the most significant impact on improving your stormwater runoff?

It may happen that you will want to choose different BMPs, once you start installing or implementing them.  That’s okay!  Just be sure to update your Stormwater Pollution Prevention Plan.  Information on installing BMPs depends on which BMPs you choose.  Again, referring to the MPCA's Industrial Stormwater BMP Guidebook (will help you to get a sense of how to install structural BMPs.

Start with the simple BMPs first (such as moving materials indoors or under cover).  Many of the recommendations in Step 2:  No Exposure will be helpful as non-structural BMPs and simple structural BMPs. Remember, non-structural BMPs must be implemented before applying for permit coverage; facilities have the first full year after applying to implement structural BMPs.

Employee training

Employee training should be a major component of any SWPPP. Employee training is also an integral part of other control measures. In order for the SWPPP to be effective, employees should be informed about stormwater treatment and control measures at the facility. They should understand their role in stormwater pollution prevention at the facility. Employee training for stormwater issues may be done in conjunction with other training programs.

The purpose of a training program is to teach personnel at all levels of responsibility the components of the SWPPP. When properly trained, staff are more capable of preventing spills, responding safely and effectively to an accident, and recognizing situations that could lead to accidents. Employee training as a control measure is an ongoing process, which may take some time to implement. All new employees should be trained as soon as possible. The complexity of the BMPs, the turn-around time of the employees, and the effectiveness of the training will affect how often training sessions will need to be scheduled.

Employee Training Documentation 

Be sure to document within the SWPPP a training schedule and the planned training frequency.  Include a record of the trainer and the trainer’s organization (internal or external), as well as the names of trained individual(s) and dates that the individual(s) received training.  This documentation can be either in the SWPPP or in a separate record.

The following individuals should be trained at least annually:

• Employee(s) overseeing implementation of, revising, and amending the SWPPP
• Employee(s) overseeing implementation of, revising and amending the SWPPP
• Employee(s) performing installation, inspection, maintenance and repair of BMPs;
• Employee(s) who work in areas of industrial activity subject to the permit; and
• Employee(s) who conduct stormwater discharge monitoring 

Training should cover the components and goals of the SWPPP and include:

• Spill response procedures
• Good housekeeping
• Material management practices
• Stormwater discharge monitoring procedures
• BMP operation and maintenance

Training suggestions:

• Frequently conduct proper training of employees in good housekeeping techniques and proper safety methods to reduce the potential that materials or equipment will be mishandled. It also reduces the chance of injury, loss of materials, and release of contaminants.
• Incorporate information sessions on good housekeeping practices into employee training programs.
• Discuss good housekeeping at employee meetings
• Promote pollution prevention concepts through posters, brochures, newsletters, etc.
• Post bulletin boards with updated good housekeeping procedure tips and reminders.

University of Minnesota Training Opportunities

MPCA is joining with the University of Minnesota to offer a variety of training opportunities.  For class options and locations, visit the University of Minnesota Erosion and Sediment Control Certification Program.  

Looking for sector or industry-specific training? Contact The U of M Erosion and Sediment Control Certification Program directly:  800-646-2282 or 612-625-9733 or email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it. .

Employee Training Resources

• Michigan Department of Natural Resources and Environment Industrial Stormwater Training Manual 
• Michigan’s training video.

Go to Step 9