Spill Types
Review major spill types and why it’s critical to have a plan.
Spill Prevention and Planning
This article provides an overview of eight important spill regulations that any manufacturing facility should be familiar with.
We will cover spill prevention best practices, how to create a spill prevention plan for compliance with OSHA, EPA, and local agencies, and what to do if a spill occurs at your facility.
We divided the content into six topics. Let’s get started.
Review major spill types and why it’s critical to have a plan.
Our top 8 from the major players – OSHA, EPA, and local agencies.
What plans are needed for your facility, and what should go in them?
Are spill kits required, and what should go in them?
Six critical steps to handling a spill.
Who to contact for more information.
Spills can come in all shapes, sizes, and substances. Most spills can be grouped into one of four major categories – chemicals, oil, raw material, or air pollutants. You can use SDS sheets at your facility to identify the specifics of a potential spill.
Critical planning and prevention come into play BEFORE a spill happens. This is when you will:
If all your due diligence is handled up front, you’ll be well on your way to preventing spills of all kinds – from minor slip accident to a catastrophic containment breach.
Bottom line. Spill planning is critical. If you don’t have one in place, please keep reading.
The major players in spill compliance are OSHA, EPA, and local agencies. In the infographic below, you can see a general overview of these major players. While we’ve listed the top 8 regulations related to spills, you can see that with all the local and state regulations, the regulations are countless!
OSHA is concerned about the safety of people. In the event of a spill, OSHA wants to ensure workers are kept safe from slip hazards, toxic inhalation, chemicals getting on skin, etc.
Below are our top 8 industry requirements from OSHA related to spills.
Where to Learn More:
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9714
HAZWOPER Decision Guide. Source: https://www.osha.gov/SLTC/emergencypreparedness/hazwoper/
While OSHA looks out for workplace safety, EPA is concerned about preserving waterways, soils, and quality of air. For example, will the spill leach into the ground or sewers at your facility?
The RCRA regulations are contained in title 40 of the Code of Federal Regulations (CFR) parts 239 through 282. The CFR is a collection of all federal regulations codified and enforced by all federal agencies. Title 40 – Protection of the Environment – contains all of the regulations governing EPA’s programs.
Title 40 includes standards for proper storage, containment, and management of waste at your facility.
Before a facility is subject to the SPCC Rule, it must meet three criteria:
Does SPCC apply to your facility? Follow this link to find out: https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/does-spill-prevention-control-and-countermeasure
Where to Learn More:
https://www.epa.gov/epcra/local-emergency-planning-committees
As part of the Oil Pollution Prevention regulation, the FRP rule addresses:
In addition to EPA and OSHA federal regulations, you should also be aware of any regulations from your state environmental protection agency, the local health department, and other local government requirements.
The following spill plans may be required for your facility:
EPA recognizes that SPPC plans or Hazardous Chemical Inventory reports may address some components of a slug plan.
If your facility does not fall into the requirements for one of the standardized plans above, it’s an industry best practice to have a plan in place if there is potential for spills at your facility.
While there are many OSHA and EPA requirements on how to be prepared for spills, the regulations do not specifically require spills kits. However, spill kits are a good best management practice under the SPCC rule. A spill kit can:
What you put in the spill kit depends on the potential spill size, type of spill, and if workers will have the appropriate PPE available.
Spill kits are generally good for spills up to around 100 gallons. After that, additional tools and methods might be needed, such as a pump.
Despite all of the prevention methods put in place, spills can happen. It’s important to have a plan in place to quickly contain and stop the spill. Below are some of the key steps to properly handle a spill.
In the event of a spill, employees should be trained to quickly assess and identify the following:
OSHA defines an incidental release or spill as “a release of a hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency.” Incidental spills do not require an emergency response, and therefore do not require HAZWOPER-trained cleanup personnel. They may be cleaned up by employees working in the area where the spill occurred or by maintenance personnel.
Employees should know what they can and cannot cleanup in the case of a spill.
Notify personnel and isolate the area so that others do not slip or fall. Close a nearby door if possible. Notify emergency groups such as the fire department, ambulance, EHS officer, regulatory agencies and public safety if necessary.
Stop the spill at the source when safely possible. Turn off the machine, plug the leak, or do what is needed to stop the spill from growing even larger. Ventilate the area if needed. Stop the spill from spreading with absorbent socks, mats, mops, or other material per your spill plan.
Use appropriate spill cleanup material per your plan. This can include oil absorbents, mops, and/or a liquid pump. Decontaminate if necessary.
Report the spill if it meets reportable standards from OSHA or EPA.
Always perform a root cause analysis and reassess control measures throughout your facility to prevent another spill.
Replenish your cleanup supplies to ensure you are prepared for another spill.
There are many types of spills – from chemicals, to oil, to air pollutants. There are also many agencies that regulate the prevention and handling of these spills. Whether you meet the criteria for these spill compliance standards, you should always have a plan in place when there is the potential for a spill.
It can sometimes get confusing to keep track of who to contact and for what issue. For example, the EPA does not handle all environmental concerns, as many programs have been delegated to individual states. Here is a quick list of who to contact:
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