Training Required by the EPA Construction General Permit (CGP)

CGP 6.1 STORMWATER TEAM 

Each operator, or group of multiple operators, must assemble a “stormwater team” that will be responsible for carrying out activities necessary to comply with this permit. The stormwater team must include the following people: 

• Personnel who are responsible for the design, installation, maintenance, and/or repair of stormwater controls (including pollution prevention controls); 

• Personnel responsible for the application and storage of treatment chemicals (if applicable);

• Personnel who are responsible for conducting inspections as required in Part 4.1; and 79 

CAP 6.2 GENERAL TRAINING REQUIREMENTS FOR STORMWATER TEAM MEMBERS 

Prior to the commencement of construction activities, you must ensure that all persons assigned to the stormwater team understand the requirements of this permit and their specific responsibilities with respect to those requirements, including the following related to the scope of their job duties:

• The permit requirements and deadlines associated with installation, maintenance, and removal of stormwater controls, as well as site stabilization; 

• The location of all stormwater controls on the site required by this permit and how they are to be maintained; 

• The proper procedures to follow with respect to the permit’s pollution prevention requirements;

When and how to conduct inspections, record applicable findings, and take corrective actions. 

Specific training requirements for persons conducting site inspections are included in Part 6.3. 

You are responsible for ensuring that all activities on the site comply with the requirements of this permit. 

You are not required to provide or document formal training for subcontractors or other outside service providers (unless the subcontractors or outside service providers are responsible for conducting the inspections required in Part 4, in which case you must provide such documentation consistent with Part 7.2.2), but you must ensure that such personnel understand any requirements of this permit that may be affected by the work they are subcontracted to perform. 

 If the person requiring training is a new employee who starts after you commence construction activities, you must ensure that this person has the proper understanding as required above prior to assuming particular responsibilities related to compliance with this permit. For emergency-related projects, the requirement to train personnel prior to commencement of construction activities does not apply, however, such personnel must have the required training prior to NOI submission. 

If one of the following topics (e.g., installation and maintenance of pollution prevention practices) is not covered by the non-EPA training program, you may consider supplementing the training with the analogous module of the EPA course (e.g., Module 4) that covers the missing topic. 

CGP 6.3 TRAINING REQUIREMENTS FOR PERSONS CONDUCTING INSPECTIONS 

For projects that receive coverage under this permit on or after February 17, 2023, to be considered a qualified person under Part 4.1 for conducting inspections under Part 4, you must, at a minimum, either:

• Have completed the EPA construction inspection course developed for this permit and have passed the exam; or

• Hold a current valid construction inspection certification or license from a program that, at a minimum, covers the following:

• Principles and practices of erosion and sediment control and pollution prevention practices at construction sites;

• Proper installation and maintenance of erosion and sediment controls and pollution prevention practices used at construction sites; and 

• Performance of inspections, including the proper completion of required reports and documentation, consistent with the requirements of Part 4.