If you have an SPCC Plan, regardless of which type, you need to do monthly inspections. And, you need to keep records of the inspections. Here we discuss the top 10 things to do, look for, or pay attention to when you conduct your monthly inspections.
We do a ton of SPCC Plans, and if there's one area that everyone seems to struggle with, it's the ongoing monthly inspections. We've heard every excuse in the book, from I don't have the time, to it's confusing, to nothing every changes, so why even do them?
It just seems that so many people get hung up on doing the actual inspections. What gives?
The inspection sheet we give our clients as part of their SPCC Plans is a one page, double sided list of target areas that we've seen as usually needing inspecting at facilities. The list is short, and it shouldn't take a lot of time to do, because we think monthly inspections should be short and sweet, and because you've probably got other more important things to be doing.
Top 10 Things To Do For SPCC Plan Monthly Inspections
Just keep in mind, these inspection ideas are applicable for any type of plan, including Tier I, Self Certified, or PE Certified Plan. And, while this list is basic, we've found these points are applicable at most facilites we've ever created a plan for.
- Actually do them. Kind of obvious, but actually do your inspections. Inspect your tanks and fill out the forms. You're required to. If you don't, you're not in compliance, and you could get in trouble.
- And actually inspect your tanks. I hate to hear people say "I just copied last month's form" or "I just look out my window". That's not an inspection and you're not doing them correctly. You're lying and filling out documents that say otherwise. That could get you into a whole lot of trouble with a lot of different people. Don't risk it. Go outside, look at your tanks, and do your inspections.
- Document your inspections. Keep track of what you're seeing. Either use inspection sheets that come with your SPCC Plan, or develop a comprehensive inspection checklist on your own. Be thorough and document what you find.
- Keep your results. Keep records in your plan, start a folder or a notebook specifically for site inspections, or a file them on your computer. Just make sure you keep your results in one place. I recommend keeping inspection results for 5 years.
- Remember the annual inspection. You need to do one annual inspection in order to be fully compliant. Do it at the same time as your monthly inspection. Kill two birds with one stone, and get back to business.
- Double check your plan. Have things moved? Has the site changed? Are there new tanks? Have there been any spills? Make sure you keep your plan up-to-date. Your inspections should reflect accurate and current site conditions. I've seen countless inspection sheets filled out and inspection results for tanks that have been removed from site for years. I don't like seeing it, and regulators doing site inspections really won't like seeing it.
- Address reoccurring problems. Are you seeing the same thing month after month? Nozzles left on the ground? Fill ports being left unlocked? Trash being thrown in secondary containment? Address these problems to prevent a bigger, more serious issue down the road. Your oil tanks are a hazard filled with highly flammable liquid, and should be treated as such.
- Train your staff. It's a great idea to spread the responsibility around each month. Have another staff member, maybe someone who sees the tanks daily, do the inspection with you so they learn why monthly inspections are necessary, and they can learn how to identify problems before they become serious. Best part is, you could count this inspection as SPCC training! You can kill two birds with one stone here.
- Keep your signs and placards legible. If something breaks, falls off, or gets painted over, make sure it's replaced. This is probably the number one thing with inspections that gets overlooked. Just because you know, or the plant manager knows what's in a tank or drum, doesn't mean everyone else will. In this instance, have someone do the inspection with you who's unfamiliar with the tanks. If they can't figure out exactly what's in a tank, and if it's hazardous, then chances are it's not in compliance with SPCC regulations. Either purchase signs, paint them (clearly & legibly), or talk to vendors and get appropriate placards. A sticker for a 55-gallon drum of hydraulic oil should never be used as a placard for a 275-gallon tank of hydraulic oil.
- Develop A Clean Environment Keep your facility as clean and clutter free as possible. Get rid of empty drums or unused tanks, and talk to vendors to get old totes or tanks out. Fewer oil containers means fewer things to inspect. An empty drum is still regulated by SPCC regulations. Get them off site and out of mind.
These are pretty generic concepts for monthly inspections. Larger facilities might need to do a lot more work for monthly inspections. Additionally, depending on your state (and sometimes county or city), you may have more stringent inspection requirements for oil containers. If that's the case, use those inspections sheets as your monthly SPCC inspections. There is no form or guidelines to follow as per SPCC regulations, so use whatever makes your life easier.
And remember, just do your inspections.
It's an easy thing to overlook, and can carry significant penalties if you don't actually do them, so take the time, and do your monthly inspections. If your operation could benefit from SPCC training, or your struggling with your monthly inspections, click here to contact us or give us a call at 609-693-8301 today.