In a previous article I presented an overview of OSHA and ISO45001. This article focuses on the EPA regulation and ISO 14001 requirement (Compliance Obligations and Emergency Preparedness) for Spill Prevention, Control and Countermeasure commonly referred to as SPCC. In 1973, the Environmental Protection Agency (EPA) issued the rule to address the oil spill prevention provisions contained in the Clean Water Act of 1972. The regulation forms the basis for EPA’s Oil Spill Prevention, Control, Countermeasure Program, which seeks to prevent oil spills from above ground and underground storage tanks.

SPCC Plans are developed as the cornerstone of EPA’s strategy to prevent oil spills. This requires organizations to identify, develop and deploy Best Management Practices for containment and other countermeasures to prevent oil spills from reaching navigable waters.

SPCC Plans require a spill contingency plan if a facility is not able to provide adequate containment for all oil storage. This includes an emergency response plan for spills, tank ruptures and equipment malfunction. An organization must report certain discharges promptly to regulatory agencies based on state or federal requirements for quantity of the spill. The EPA periodically conducts on-site inspection to ensure compliance with the regulation.

A typical SPCC Plan contains

• A description of the facility that includes storage locations
  1. Oil reservoirs
  2. Hydraulic and machine lubricates in new oil storage room
  3. Drums of oil on racks in maintenance building
  4. Motor oil stored in mobile maintenance building on SPCC
• Contact Information for the facility as well as for emergencies
• Operating procedures and controls that are established to prevent oil spills.
• Countermeasure plans to contain, clean up and mitigate the effects of an oil spill. This may include operational controls such as
  1. Monthly Inspections
  2. Spill kits
  3. Dikes, berms or retaining walls
  4. Sumps & collection systems
  5. Culverting, gutters, or other types of drainage systems
  6. Weirs, booms or other barriers
  7. Absorbent materials (i.e. pigs)
  8. Spill Response Plan
     • Identify (Who, What, When, Where, Why)
     • Notify
     • Secure (Cordon off spill site)
     • Control / Contain
     • Clean Up (No solvents down drains)
     • Decontaminate (Clean tools and isolate any contaminated clothing)
     • Paperwork (Incident and/or chemical spill reports)
• Forms used for reporting spills
• Training requirements for employees

To summarize, a well-developed plan, emergency response and reporting are essential for fulfillment of this regulatory requirement. Operational controls as part of the ISO 14001 requirements support and are included in the SPCC plan.