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What needs to be included in my spill prevention control and countermeasure plan?
Responding is Carlo Emanuele, product manager for spill prevention control, Brady Worldwide Inc., Milwaukee.
Creating and implementing a spill prevention control and countermeasure plan is required by the Environmental Protection Agency to prevent the discharge of oil and spills. An SPCC plan should identify proactive measures to prevent a spill from occurring or reaching the environment. In addition to meeting EPA regulations, an SPCC plan can help prevent slips, trips and falls from occurring within your work environment.
When developing your SPCC plan, make it specific to your facility’s layout, storage and key contacts. It should include:
1. Operating procedures that prevent oil spills
Employees are trained to implement spill prevention practices for work with and around oil sources. This section of your plan outlines best practices, recommendations and training procedures such as:
- Storage instructions (i.e., do not store oil sources near catch basins or floor drains)
- Management practices (i.e., always have supervision during the loading and unloading of petroleum products)
- Product recommendations (i.e., use pads, drip pans and funnels when transferring petroleum products from a portable container)
- Layout maps (i.e., facility map that denotes location and contents of each container, tank, transfer station and piping)
2. Control measures to prevent a spill from reaching the environment
This section of the plan should identify the types and locations of spill-containment products in order to quickly control a spill. For example, maintaining stocked spill kits at spill-prone locations, and ensuring this is documented within your plan, can increase the likelihood that responders will be able to handle a spill before it becomes reportable. It also is important to keep a combination of absorbent products stocked and onsite, such as booms, pads and socs.
3. Countermeasures to contain, clean up and mitigate the effects of an oil spill that reaches the environment
When a spill is not prevented from reaching 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 conduct a survey of 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 represents the independent views of the author and should not be construed as a National Safety Council endorsement.