Spill Prevention and Response
Spills can halt operations, fuel fires and explosions, endanger workers and the public, contaminate drinking water, and lead to hefty government fines! You might say it’s not “if” chemical spills will happen but “when.” Now is the time to get ready, before facing a costly spill event that could shut down your business. Preventing spills constitutes the best method for mitigating damage. At the same time, it’s important to have a spill response plan. Simply thinking you’ll just call 911 is not a spill plan. Because the success of any spill control operation depends on minimizing the volume of what’s spilled, having readily available response equipment and a trained response team is also a must.
What You Need to Know
Government agencies often require you to prevent spills, be ready to respond promptly once they occur, and/or notify authorities as required. These agencies include OSHA, EPA, and DOT, among others. A few spill-related regulations that quickly jump to mind include:
- OSHA 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER) — This standard covers emergency spills of hazardous substances at any site, not just abandoned hazardous waste cleanup sites and sites that treat, store, or dispose of hazardous waste.
- EPA 40 CFR 112, Oil Spill Prevention, Control, and Countermeasures (SPCC) — This comprehensive standard aims to protect navigable waters and adjoining shorelines from oil discharges. The four cornerstones of this standard are the written SPCC plan, secondary containment, inspection/testing, and spill notification.
- DOT 49 CFR 172 Subpart G, Emergency Response Information — Under this subpart, hazardous materials (hazmat) shipments that require shipping papers also mandate emergency response information to accompany the shipment. Some hazmat incidents require immediate reporting too.
However, you cannot stop there. Ensure you meet ALL applicable spill-related regulations. At the federal level, several other regulations stand out as listed below, but this list, believe it or not, is not all-inclusive:
- OSHA 29 CFR 1904.39, 1910.22, 1910.38, 1910.106, 1910.110, 1910.119, 1910.178, and 1910.1200.
- DOT 49 CFR 130, 171.15, and 171.16.
- EPA 40 CFR 68, 110, 116, 117, 118, 122, 165 Subpart E, 170, 262, 264, 265, 266, 273, 279, 280, 302, 355, 372, 403.8, 403.12, 430.03, 440.148, 455, 761.65, and 761.125.
- Chemical Safety and Hazard Investigation Board (CSB) 40 CFR 1604.
Note that state and local jurisdictions may call for further measures.
Let J. J. Keller help navigate these complex rules and regulations that address spill prevention and response. Learn how to apply spill prevention best practices and adequately prepare for spill response.
Spill prevention is the most effective action your business can take. A primary way to prevent spills is with secondary containment. It provides temporary containment of spilled chemical if the primary container fails. Secondary containment gives you time to abate the source of the spill and remove the accumulated chemical to prevent it from reaching waterbodies.
Other typical spill prevention methods include using overfill prevention, corrosion protection, container inspection/testing, security measures, housekeeping, and following safety data sheets for handling and storing any chemical containers.
To handle spills effectively, planning is essential. When a spill occurs, decisive action is required. Response plan requirements will vary by regulation. However, core elements typically include, but are not limited to:
- Identifying facility and contact information;
- Personnel roles, lines of authority, training, and drills;
- Site mapping, evacuation routes, and places of refuge;
- Emergency equipment and resources;
- Procedures for discovery, assessment, notification, and evacuation;
- Rescue, medical treatment, and first-aid procedures;
- Response procedures, along with response termination and follow-up actions; and
- Plan review and updating.
Because several agencies (including OSHA, EPA, DOT, and others) mandate some sort of spill response plan, let us help you determine which agency plans and plan elements are required for your facilities!
Spill response equipment, such as well-stocked spill kits and carts, are necessary to control hazardous spill conditions and clean up a spill. It is also important that you have the necessary resources, namely personal protective equipment (PPE) and chemical protective clothing (CPC), available to protect response personnel. When selecting the type and quantity of response equipment, you should think about not only probable spills that may arise but also the worst-case scenario. Consider the hazards to site employees who may be exposed, along with appropriate containment, mitigative, and protective measures that may be needed. Also, weigh any off-site responder capabilities and their arrival time, the number of victims possible, and the number of response personnel available to engage.
For more details browse our spill control kits and PPE Personal Protective Equipment products and our various training solutions.
It is equally important to equip your employees with the knowledge required to respond. Anyone actively involved in spill control must be thoroughly familiar with the procedures involved and must be trained to work safely. In fact, responders must understand not only the hazards presented, but the potential hazards that could arise. Training helps workers recognize when a spill presents or will present a hazard. It also ensures that they learn to assess a situation, understand what they can safely handle, and know how to respond safely.
When people think of spill-response training, OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard often comes up with its initial and annual refresher training in one of five responder training levels. However, keep in mind that you may need to also consider other federal and state training laws and regulations.
Please check out our training solutions for workplace safety, environmental, and transport topics.
