What needs to be incorporated in my spill prevention restriction and countermeasure program?
Planning and executing a spill prevention control and countermeasure plan is expected by the Environmental Protection Agency (EPA) to limit the discharge of oil and other spills. An SPCC plan should recognize proactive actions to limit a spill from occurring or reaching the environment. In addition to meeting EPA commands, an SPCC plan can help limit slips, trips and drops from happening inside your business environment.
When forming your SPCC plan, make it specific to your facility’s layout, storage and key contacts. It should include:
1. Operating methods that limit oil spills
Employees are guided to implement spill prevention techniques for achievement with and around oil reservoirs. This section of your plan outlines best practices, recommendations and teaching methods such as:
Management practices (i.e., always have supervision during the loading and unloading of petroleum products)
Product recommendations (i.e., use pads, drip pans, and ducts when transferring oil stocks from a portable container)
Layout maps (i.e., facility map that denotes location and contents of each container, tank, transfer pumps and piping)
2. Control measures to avert a spill from spreading to the environment
This section of the plan should recognize the kinds and locations of spill-containment products to control a spill quickly. For example, maintaining stocked spill kits at spill-prone areas, and ensuring this is documented inside your plan, can enhance the likelihood that responders will be able to handle a spill before it becomes reportable. It also is essential to keep a combination of absorbent products stocked and onsite, such as booms, pads and socs.
3. Countermeasures to contain, wash up and mitigate the effects of an oil spill that reaches the environment
When a spill is not contained from entering the environment, quick-response countermeasures need to be in place. Within this section of the plan, facilities should identify proper evacuation policies, authorized employees for cleanup and contact information.
Creating your own SPCC plan gives you the flexibility to tailor it directly to your facility while complying with EPA requirements. You can further enhance the specifics of your plan by arranging for a third-party organization to survey your facility, focusing on absorbent technology, products and regulations that could affect the needs of your business. A detailed plan can positively contribute to improved housekeeping practices and controlled spills and discharges.
Editor's note: This article describes the nonpartisan views of the author and should not be construed as a National Safety Council endorsement.
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If you don’t have secondary containment, you need spill containment. If you do have secondary containment, you furthermore need spill containment.
To understand the role of each type of containment and why you should have both, read on.
The act of obstructing a spill is spill containment. When there’s a spill, your number one priority — after addressing safety concerns — is to prevent it from spreading. The sooner you contain the spill, the smaller the area that is affected. And that means less time spent cleaning up the spill.
The most important thing to remember is that spill containment is part of the spill response. Spill response procedures often contain different types of spill containment to address multiple types of spills, including absorbent non-absorbent dikes, socks, and booms, or even drainage sumps created to collect spilled liquids. For example, spill containment for a ten-gallon oil spill in a warehouse with no floor drains might call for absorbent mats and a few socks, but spill containment for a 30,000-gallon fuel spill traveling toward a nearby river is going to take a full stockpile of absorbents, booms, and sumps to control it.
Drums, totes, and tanks are examples of primary containers. These containers normally retain their liquid contents without incident. But if they contain a hazardous material, and because they can potentially fail, the EPA requires them to have secondary containment.
The EPA doesn’t specify specifically what secondary containment must look like, but they are definite about what it needs to do: If the primary container fails, the secondary containment structure or device must be able to hold the entire volume that could spill until it can be cleaned up.
That means that secondary containment can be anything from spill pallets or decks to a sloped room that allows the liquid to accumulate at one end until it can be cleaned up. It could be dikes, berms or concrete walls that create a moat around the primary container. In some cases, it can even be absorbents. It’s up to you to evaluate your circumstances and choose the best resolutions for your needs.
Why You Should Have Both
Even super-sturdy secondary containment systems can fail and cause a spill, so the EPA requires you to be prepared for spills with appropriate spill containment — even if every container at your facility has secondary containment. That’s why, when people ask us if they need spill containment or secondary containment, our answer is always, “Yes!”