On April 4, 2017, the State Water Resources Control Board (Board) adopted several revisions to its Enforcement Policy regarding financial penalties for violations of the State Water Code or Federal Clean Water Act. The Board has been expanding its enforcement staff and their activities and the change in policy is designed to increase penalties for violations. Under the prior policy that was adopted in 2010, dischargers that did not have a history of violations could receive some consideration when the Board calculated penalties for new violations. In those cases, the“History of Violations”factor multiplier could be set at a value of less than one at the dis- cretion of the Board. The new rule stipulates that dischargers with no history of violations will be assigned a factor of one, eliminating the option of acknowledging a good compliance history with a lesser factor. CLFP opposed this change and requested that the enforcement staff have the discretion to assign multipliers of less than one to acknowledge past compliance and cooperation. The 2010 Enforcement Policy stipulated that dischargers with a track record of violations could be assigned a“History of Violations”factor of up to 1.5 to increase the severity of the financial penalty. The new rule states that the Board should use a minimum multiplier of 1.1 and eliminated the 1.5 factor ceiling. This change does not provide the regulatory staff with sufficient guidance as to appropriate maximum penalty levels, and without a prescribed ceiling unreasonably high and arbitrary factors could be assigned. CLFP and other organizations opposed this change. State Water Board Revised Enforcement Policy 8 News & Views Magazine EDITION 1, 2017 Employers can select any combination of internal or external California-based training providers. An internal trainer can be a foreman or any onsite subject-matter expert. External paid vendors who are industry experts can be brought in and training can be provided in a laboratory setting, class- room or computer based. A local community college or school may also be contracted for training. According to Duffy, Trinchero used some outside vendors for some of the classroom training needs, but their entire produc- tive lab raining was carried out by experienced employees. Training topics can consist of one subject or a combination of topics, including: business skills such as customer service, accounting, marketing or social media; computer skills such as Microsoft Office, Excel and Access; continuous improve- ment, such as lean manufacturing, quality control and team building; management skills such as leading a team and supervisory skills; manufacturing and warehousing skills such as cross-training in production operations; and OSHA 10/30 and Hazmat training. A food processor can request progress payments during training, receiving 25 percent at trainee enrollment, 50 percent at completion of all training, and 25 percent upon the successful completion of the 90-day post-retention period. Many have said“this looks too good to be real, what’s the catch?”The catch is you must have the need for the training, the commitment to deliver the training and the desire to provide better skills to your workers. For more information about the program and applying, please visit www.etp.ca.gov. For questions or assistance about the California reimbursement money through ETP, contact Renee Pierce at Renee.Pierce@etp.ca.gov or call 916-327-5258 or Barry Worthington at Barry.Worthington@etp.ca.gov or 916-327-5262. A food processor can request progress payments during training, receiving 25 percent at trainee enrollment, 50 percent at completion of all training, and 25 percent upon the successful completion of the 90-day post-retention period. By ROB NEENAN - CLFP President & CEO