Learn whether 55-gallon drums are included in a SPCC Plan.
A question we see frequently is are 55-gallon drums included in an SPCC Plan? It's a simple enough question, with a simple enough answer. This is a vital thing to understand, because by having just two dozen 55-gallon drums of oil or petroleum product on-site, you meet the need for an SPCC Plan.
Let's look at a hypothetical garage or maintenance building at any type of facility located in the US. Besides tools, lights, vehicles, etc., what's one guarantee you're going to see in each and every garage? 55-gallon drums. You can bet that you'll find a couple of drums of various materials. More often than not, these drums might contain a petroleum-based product, like motor oil, or hydraulic oil.
The real question is...
Are 55-gallon drums included in a SPCC Plan?
Plain and simple, yes. All 55-gallon drums of petroleum-based products must be included in a Spill Prevention Control & Countermeasure Plan. Regulations state that containers 55-gallons or larger have to be included in your plan.
Seems simple enough, but we've found that people tend to think of "tanks" of oil, and ignore drums altogether. The majority of our clients used to never consider these drums part of their SPCC Plan. So what's that mean? They were out of compliance with SPCC regulations for not including 55-gallon drums of oil products.
So let's spell this out. If your facility has over 1,320 gallons of oil on-site (including full, partially full, and empty drums or tanks), you need a plan. If your facility has more than twenty-four 55-gallon drums of oil products, you need a Spill Prevention Control & Countermeasure Plan.
What about other sized drums in SPCC Plans?
How about a 30-gallon drum? Or a 16-gallon drum? They do not have to be included. If you want to list everything, go right ahead, but they do not count towards the total 1,320-gallon threshold. Only 55-gallon drums and larger.
Here are a few tips with regards to drums and your Spill Prevention Control & Countermeasure Plan:
Only include oil products. No anti-freeze, DEF, etc. Things like vegetable or animal oils also need to be included! Just remember, SPCC regulations only apply to oils and petroleum products.
When you count 55-gallon drums, count everything. That includes drums that are sealed and full, drums that are half full, and drums that are empty waiting. SPCC regulations count any 55-gallon oil product drums, regardless of how much product is left in it, as full. If you're not going to use the drum, clean it, cut it, get rid of it, whatever! Just don't let them build up on-site.
Always round up when counting drums. If you do an inventory and find you have 30 drums on site, round up. I've yet to visit a facility that doesn't occasionally get in extra drums for whatever reason, or have a delay in getting rid of empty drums. Consider your on-hand amount to be your 'average', and maybe your 'maximum' is plus an extra 50%. In this example, your average is 30 drums, and your maximum is 45. You can always have less than your Spill Prevention Control & Countermeasure Plan says, but when you have more, you could be in trouble.
So there's no escaping just because all your oil or petroleum is in 55-gallon drums. If you're over the threshold of 1,320 gallons, you need a Spill Prevention Control & Countermeasure Plan.
Remember, that's not a bad thing. This isn't a permit. There's no fee to the government, and when you do get inspected, a well-maintained plan should get the inspectors in and out fairly quickly. Having a good, usable plan you and your staff know (meaning annual SPCC Training) and can understand can bring a variety of benefits, like having a documented program for preventing and dealing with any spills (including non-petroleum products) should they occur.