Earlier this year, the US EPA cited a company for not having trained staff on-site at all times the Extremely Hazardous Substance (EHS) or Highly Hazardous Chemical (HHC) is on-site in quantities that exceed the Risk Management Plan threshold. The case (Click Here for my summary of the case) involved an ammonia distributor. The only time trained personnel were on site was when a truck was loaded or unloaded. This is clearly a staffing issue; but, there is so much more to “process staffing” than just having operators on site.