Speaking of Spills: These 10 Tips for SPCC Compliance and Accident Preparedness Will Help You Meet the Upcoming Deadline

By Lorenz, Joe | Occupational Hazards, May 2006 | Go to article overview

Speaking of Spills: These 10 Tips for SPCC Compliance and Accident Preparedness Will Help You Meet the Upcoming Deadline


Lorenz, Joe, Occupational Hazards


In October 2007, facilities across the country will be staring into the eyes of a looming compliance deadline for SPCC plan changes, wishing they could turn back the clock. Even though facilities have well over a year to prepare, the unfortunate truth is that many will fail to get up to speed in time. The culprit, in most cases, is a failure to plan ahead and stay informed on the new regulations.

The revised SPCC (Spill Prevention, Control and Countermeasure) rule, which dates back to 1974, became a formalized amendment to the Oil Pollution Prevention regulation in 2002. The objective of the rule is to prevent oil spills from reaching the nation's waters. Unlike contingency plans, which address cleanup measures after a spill has occurred, SPCC plans emphasize preventive measures to avoid spills, or effectively contain and remove them.

Written SPCC plans describe all of an operation's oil storage and spill prevention measures, as well as personnel training and facility security. Prevention measures include an outline of the procedures to be followed by facility personnel in the event of a release. The plan also must include a history of facility spills and any near-miss incidents that have occurred.

Facilities operating before August 2002 are required to amend and implement their existing plans by Oct. 31, 2007. Newer facilities that began operating since 2002 must prepare and implement their plans by the same October deadline. After Oct. 31, any newly established facility must prepare and implement its SPCC plan before it can begin operation.

WHAT YOU SHOULD DO

The process of meeting any type of compliance deadline has developed a bad reputation, particularly regarding government regulations for facilities. But is the stress really necessary? Staying in touch with the regulations, utilizing engineering and environment consultants and planning ahead can solve many of the problems associated with meeting these requirements. Here are 10 important tips regarding SPCC plans and general accident preparedness:

1. Stay up-to-date with regulations: It sounds simple enough, but too often companies concentrate on other aspects of their operation and miss important rule changes for SPCC plans and other mandates. Environmental contractors and professional engineers are the most valuable information source for keeping informed of all requirements. For example, some operations fail to realize that a secondary containment system must account for, as a general rule, 110 percent of the tank's capacity--not the amount that they usually store in the tank. Also, storage tanks that are not in use are still subject to SPCC regulation. Even though the tank does not contain product, it must be accounted for in the SPCC plan, it must possess all of the required containment systems for its capacity and it must undergo integrity testing.

2. Avoid overextending in-house spill teams: It's no secret that internal operations are an important part of preparing for any type of accident, and in-house spill teams often serve a vital purpose. But when an accident occurs, involving facility employees in response efforts, repairs and cleanup work can put otherwise productive workers into unsafe scenarios. Costs associated with medical care, insurance premiums, workers' compensation claims and lost productivity can quickly add up. Preparedness plans should account for the safety and productivity of all staff members.

3. Establish a service agreement with an emergency response contractor: Aside from safety and productivity issues related to handling a spill with internal staff, an agreement with a qualified emergency response contractor ensures that professionals will be on-hand when needed. With an agreement in place, the contractor will become familiar with a facility in advance, knowing the types of materials the operation handles and the secondary containment measures that are in place. …

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