The vendor and contractor training requirements in the 2025 Industrial Stormwater General Permit have been one of the more talked-about updates since the draft permit was released. Many facilities have expressed uncertainty about what counts as training, who it applies to, and how to document it. During our recent discussion, we walked through the permit language, heard from permittees about their current approaches, and gathered questions that were later shared with Ecology for clarification.

Summary of Permit Requirements

Who Needs Training

The permit requires SWPPP training for:

• All employees; and

• Contractors and vendors whose work could affect stormwater quality in areas of industrial activity

Vendors/contractors may be excluded from direct training if:

• They are continuously supervised by an on-site employee who has been trained on the SWPPP while that work is being performed.

  • *Note: it has been clarified from Ecology that based on the permit language, this must be an employee of your facility who is supervising, not an employee of the vendor/ contractor

What to Include in the Training

The ISGP requires that your training must cover these 3 topics at minimum:

1. An overview of what is is in the SWPPP, who is responsible for maintaining the SWPPP, and its location on site
2. How employees make a difference in complying with the SWPPP, preventing contamination of stormwater, and their role in ensuring BMPs are properly maintained and in place.
3. Spill response procedures, good housekeeping, maintenance requirements, and material management practices.

Putting It into Practice

While the permit requires that the training program  include the elements listed above, not all parts deserve equal emphasis during a short contractor or vendor training. In practice, the goal is to spend the most time on the topics that directly influence how a vendor or contractor interacts with stormwater. The “check-the-box” items (like where the SWPPP binder is stored) still need to be covered, but they shouldn’t take up most of the training.

How you emphasize training will depend on your site characteristics but may look something like this:

Other Training Related Requirements

Training Timing and Frequency:

• Training needs to occur annually at minimum
• Training needs to occur within 90 days of hire for full time employees, contractors, and vendors
• Training needs to occur within 30 days for part time and seasonal employees, contractors, and vendors

Training Log

• A log with the employees name and date of training needs to be kept with the SWPPP and made available upon request.

How Facilities Are Approaching Vendor and Contractor Training

When we met to discuss this topic, we wanted to understand not just what the permit says, but how facilities are actually meeting the new requirement in practice. To start, we ran a quick poll asking participants how they currently provide vendor and contractor training.

As you can see, there is no one set way that facilities are handling this training requirement and facilities are taking many different approaches to get a program that will fit within their size, resources, and number of vendors they work with.

Examples from Permittees

After the poll, we heard from two facilities who shared how they’ve put these requirements into action.

Example 1: Simple Training on a Budget

One permittee shared how they built a webpage to house their stormwater training program. This webpage covers all of the required training elements including a list of best management practices for working on site. Also imbedded in this webpage is an attestation form for the vendor or contractor to fill out acknowledging they took the training- allowing for vendors to take the training on their time and allowing for easy tracking and an electronic record of who has received the training. This permittee also has included a handout outlining all of this information for quick reference in the field.

Example 2: Bilingual training 

Another facility described how they developed a simple power point presentation for their training. This presentation covered the required training topics, included some images of key features of the site, and was made available on a computer in the site office so vendors could take the training immediately. This facility relied on bilingual employees to translate their PowerPoint slides into Spanish and assist during briefings. Instead of hiring a professional translator, they relied on staff familiar with both the site operations and the language, making the training more personal and cost-effective.

Common Themes from the Discussion

Throughout the open discussion, several themes emerged:

• Keep it short and specific. Most facilities aim for 10–15 minutes of focused training that ties directly to the vendor’s work area or tasks.

• Document everything. Whether through sign-in sheets, online forms, or signed contracts, attendees emphasized the importance of tracking who was trained and when.

• Leverage existing meetings. Some facilities are adding stormwater content to pre-existing trainings or meetings with contractors. This allows them to ensure the proper training is taken care of before work begins.

• Language accessibility matters. Providing materials in multiple languages or using bilingual staff increases comprehension and compliance.

Common Questions Answered

We took notes of the questions and scenarios that came up during the discussion and talked them over with Ecology. Below are their responses.

Definition of Vendor/ Contractor

1. Permittee has a large number of tenants occupying the industrial area. The tenants don’t have an ISGP. Is the permittee required to train these tenants? 

   A: Yes. Tenants, who have a contract/ lease agreement with the site owner/Permittee, who do not operate under their own ISGP, are considered employees and therefore need training on the SWPPP. Tenants are required to have SWPPP training if they have duties that may impact stormwater quality in areas of industrial activity.

   • What about vendors and contractors that are hired by the tenants?                                                       A: the new permit requires the training for any entity (hired, contracted, either by the permittee or their tenant) on the site that has the potential to impact stormwater quality when they do what they were hired to do

   • If these vendors and contractors that are hired by the tenant need training, does Ecology have any guidance/ success stories of how facilities can successfully track or monitor who their tenants hire?

     A:  Ecology does not possess guidance or success stories, but if we ever did, I think we should tell the landlord to ensure that their tenants report contractors/vendors to the landlord, so they can make sure they provide the stormwater training to them (assuming their work can impact stormwater).

2. Q: Permittee has customers who fuel trucks from their tanks on site. Do these customers require SWPPP training?
   A: Customers do not require training. It is the responsibility of your spills team and inspections to ensure customer activity doesn’t negatively impact stormwater. While training is not required, permittees can reduce risk in these scenarios with things like signage and supervision.
3. Q: Similarly, another permittee has a transfer station where customers (often waste management) enter the industrial area to dump loads of garbage. Do these folks require training?
   A: Again, Customers do not require training. It is the responsibility of your spills team and inspections to ensure customer activity doesn’t negatively impact stormwater. While training is not required, permittees can reduce risk in these scenarios with things like signage and supervision.

• • Q:Does this scenario change when the waste management company has a contract with the transfer station (i.e. the transfer station is the contractor tasked with taking the waste and the waste management companies are more like the customer)

    A: This would depend on specific contract language and provisions. It is recommended to closely review your contracts. If the contract outlines the waste management company coming on site as a customer, then they would not be required to be trained.

Content of Training:

4. Q: The permit says training needs to cover things like “their role in ensuring BMPs are properly maintained and in place” and “maintenance requirements”- does the content of the training need to cover all BMPs on site or just the BMPs that the contractor and vendor have the potential to interact with?
   A: Ecology allows the permittees to determine the specific content of the training as long as it meet the minimum requirements outlined in the permit. Vendors and contractors don’t have to receive training on every bmp on site, and training on BMPs specific to their duties/ work areas would be appropriate.

Training Log

5. Q: Can you clarify what needs to be included in the training log. Many permittees were under the impression that there needed to be a signed attestation included in the training log- a requirement that others chimed in and said were not in the permit. 

   A:The permit only specifies the name and date of training. Some facilities may want to obtain signatures of the trained people for liability reasons, but this is not a permit requirement.
6. Q: Permittee mentioned they have had situations where vendors refuse to provide individual names of their employees for the training log. Do you have any recommendations on how to approach this situation?
   A: Thanks for bringing this to our attention. It is a requirement of the permit to log the names and date of training for specific employees. We don’t have recommendations on how to approach this situation and would leave it up to the individual facility.

Employee vs Vendor training requirement

7. Q: A few permittees mentioned confusion as to how S3.b.4.b.5 should be interpreted. There are portions of this section that point out both employees and vendor/contractors, and some that just mention employees. Do these sections only apply to employees or are they intended to include vendors and contractors also? (see examples below)

A: These provisions, generally, apply to both employees as well as contractors and vendors.

• • Q: S3.b.4.b.5.c “The frequency/schedule of training. The Permittee shall train all employees annually, at a minimum. All employees, contractors/vendors, who have duties in areas of industrial activities must be trained within 90 days of hire.” This section calls out employees specifically as needing training annually without mentioning vendors- but in next sentence outlines vendor training timeline- do vendors and contractors need annual training?

A: Vendors and contractors who have duties that will extend beyond one year will need to be trained annually.

• • S3.b.4.b.5.d “A log of the dates on which specific employees received training. This log must be kept with the SWPPP and made available upon request.” Similarly this only mentions employees but not vendors and contractors. Do vendors and contractors need to be included in a log?

Digital vs Print log

• Q: Can we have a digital SWPPP and physical training log (or vice versa), or do all components of the SWPPP need to be in the same format.

       A: As long as both are easily accessible from the same location (i.e. the digital SWPPP is on a computer in the same office as the physical training log) they don’t necessarily need to be in the same format.