SPCC plans & SPCC regulations - the November 2011 deadline is near!
Posted on Tue, Nov 01, 2011 @ 02:21 PM
SPCC plans - do you have one if you need one? I hope you do know what a Spill Prevention, Control and Countermeasure (SPCC) plan is, because the clock that has been ticking so long is about to run out. The deadline in question is the November 10, 2011 deadline that has been delayed for so long (years actually).
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What's it mean to you?
- First, make sure you know what an SPCC plan is. This information should help learn more about SPCC plans, as well as this article I wrote.
- Secondly, know whether or not you need an SPCC plan. This posting should help you determine whether you need one.
- If you have an SPCC plan, when was the last time it was updated? They should be done every few years (every 5 years as of now), and if it's been longer than a few years, the chances are good it's out of date and needs to be updated now.
- The November 10, 2011 deadline includes some new regulatory requirements, that must be included in your updated SPCC. If you haven't updated in a while, chances are very good it won't be in compliance.
- If you have an SPCC plan, it is very worthwhile to evaluate where you stand in light of changes to the SPCC regulations, including a new simplified SPCC plan template for "Tier I" facilities (with lesser volumes of petroleum on site) which can be self-certified, instead of the requirement of a certification by a professional engineer (potentially saving you a lot of money!). If you qualify for a Tier I plan, you absolutely should do this! Update your plan to a Tier I SPCC plan today!
It is important to note that the November 10, 2011 deadline is not a deadline to have an SPCC plan - if you have needed one, you should have had one by now.
If you need an SPCC plan, get one now! Do not delay. It seems unlikely that the USEPA will be willing to overlook enforcement action given that there have been so many extensions of this deadline already.
A positive to point out about SPCC plans, is that they actually have a purpose - they can help you prevent oil spills, vandalism to oil and fuel tanks, and other catastrophes. It's good business to have an SPCC plan.
Don't chance not having an SPCC plan, or missing the deadline - get in compliance now.
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