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Living with an SPCC Plan: Training and Inspections

If your facility stores more than 1,320 gallons of oil, fuel, or oil-like products, then you probably need to have a Spill Prevention, Control, and Countermeasures (SPCC) Plan per federal rules. Perhaps you were recently appointed to be the facility SPCC coordinator and are wondering, “Where do I start?”

The development of the SPCC Plan is just the first step to maintaining compliance with these regulations. There are four main activities that your facility will need to do to maintain compliance, and they should be spelled out in the SPCC Plan.  They are:

  1. Train relevant facility staff on the SPCC Plan
  2. Conduct inspections
  3. Keep records of inspections, releases, and changes
  4. Respond to releases

In the first part of this blog series, we will discuss the first two activities to help you generally understand what is needed. For each of these topics, refer to your facility’s SPCC Plan for site-specific details.

1. Train Staff on the SPCC Plan

An SPCC Plan cannot be effective if facility staff are unaware of the plan or their roles in spill prevention and management. The most important individuals requiring training are the primary contact for the SPCC Plan (sometimes referred to as the SPCC Coordinator) and the alternate contact when the primary is unavailable. The primary contact must have authority to initiate and coordinate revisions to the SPCC Plan. Additionally, any staff working with oil/fuels, staff that might be expected to respond to a spill, and corporate contacts responsible for responding to a spill, or reporting releases to regulatory authorities, must receive comprehensive training. It is crucial for everyone to understand their role within the plan and how it relates to others’ roles for spill prevention and management to be successful.

What is included in the training?

The basic topics the training should cover include: the location of the SPCC plan, what oil storage containers or equipment are present on site, procedures for filling or dispensing oil or fuel from containers, and procedures for responding to and reporting releases. Your SPCC Plan should include a list of what topics are to be covered during the training, including any site-specific information.

Our consultants who provide training have found it helpful to include interactive release scenario examples in the training and recommend using examples of potential releases that are specific to your facility. This training should elaborate on staff response and required reporting elements. For some facilities, SPCC training might include a tour to point out the locations of oil storage containers and spill kits. For facilities with many containers in different locations, reviewing facility maps and photographs helps ensure all trainees understand what is covered.

How long is an SPCC training and can it be combined with other training?

While the regulations do not specify the length of training, allocate at least 30 to 60 minutes, depending on how many oil/fuel containers are at your facility. Training is required annually but should be revisited whenever new staff begin working with the oil/fuel, or if there are significant changes to the SPCC Plan (such as adding or removing containers). It is often convenient to hold SPCC training in conjunction with other topics related to overlapping regulations and responsibilities, so all relevant staff can efficiently obtain the necessary training at the same time.

2. Conduct Inspections

SPCC Plans require monthly and annual inspections of the oil containers listed in the Plan. Your SPCC Plan may require other inspections, depending on the type of containers or secondary containment in your facility. For example, if your tanks are in a diked area that is open to rain or snow, those areas must be inspected after a significant rain or snow event to ensure sufficient containment capacity is maintained and to document sheens on water that may prevent its discharge.

The SPCC Plan should have site-specific checklists that are to be used for monthly and annual inspections. One important thing to remember about the inspections is that you need to document who conducted the inspection, the day the inspection was done, and what was observed. During an inspection, it may be tempting to not document items that you observed because you corrected them, or not write up the inspection until everything is perfect, but that is not the right approach!  It is better to note all identified issues on the inspection forms, and how and when they were corrected.

It is normal for inspections to identify deficiencies, minor releases, or maintenance issues. Don’t let that scare you – identifying these issues is the purpose of having inspections. Noting these issues in the inspection report and documenting the corrective action provides valuable information that can be incorporated into future revisions to make your plan more effective.

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