Author: Richard DiNitto
Onsite oil, diesel, and related liquids may require that you implement a government-mandated spill management plan in the United States when certain conditions are met.
Many people are not aware that if you have 1,320 gallons or more of oil and related liquids “combined” in above-ground storage containers (or greater than 42,000 gallons “combined” in underground storage tanks), you may have to develop and put into place a Spill Prevention & Countermeasures Control (SPCC) Plan under the Oil Pollution Prevention Regulations (40 CFR 112).
The second criteria for establishing an SPCC Plan is that a release from the above storage could impact “navigable waters” and “adjoining shorelines”. This is a more difficult one to address and requires greater knowledge of your facility’s location in relation to surrounding surface water bodies and channels. Even onsite drainage ditches that channel runoff to nearby streams, etc., could place your operation within this requirement.
While many facilities may not routinely store any oils or related liquids, such as diesel, onsite for general use, they often forget to take into account emergency back-up generators. Just two of these generators can have a combined storage capacity of greater than 1,320 gallons.
It is important to note that it is the “combined quantity” of all storage onsite that counts, and not the size of just the largest tank. Two tanks of 750 gallons will exceed the threshold for application of this regulation.
If you meet the applicability requirements of these regulations, then a SPCC Plan must be prepared and certified by a professional engineer unless:
The contents of the SPCC Plan are detailed within the regulations, but broadly must contain the topics in the table below. The SPCC Plan must be maintained at the facility if manned 4 hours/per day or more, or at the nearest field office if manned less than 4 hours/per day. It is also required to be reviewed and updated every 5 years, or within 6 months of any material changes.
The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities.
If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at firstname.lastname@example.org or (617) 330-2800.
The European Commission has a feedback period for a Commission Delegated Regulation amending Regulation (EC) No. 1272/2008 of the European Parliament and of the Council on classification, labeling and packaging of substances and mixtures as regards information relating to emergency health response. The amendments would change Annex VIII on emergency health response to clarify the text and extend the first compliance deadline by one year to January 1, 2021. The feedback period closed on August 19, 2019.
If you are interested in EHS regulatory products for the European Union, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or email@example.com for a customized quote.
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