5 Common SPCC Plan Violations (and How to Avoid Them!)

The Top 5 SPCC Mistakes - and How Not to Make Them at Your Facility

Spill Prevention, Control, and Countermeasure (SPCC) plans are crucial for preventing oil spills and ensuring businesses remain compliant with environmental regulations.

However, many companies make mistakes that lead to violations, costly fines, and environmental damage. Sound stressful? Don't worry - we're about to cover five common SPCC plan violations and practical steps to avoid them.

But before we dive in, let’s address the most critical mistake: not having an SPCC plan at all! If your facility requires one and you don’t have it in place, that’s a major compliance risk. Unsure if you need an SPCC plan? Take our free online assessment or contact us at RMA for a personalized consultation. Now, let’s jump right in!

1. Inadequate Plan Documentation

One of the most frequent violations is failing to keep the SPCC plan updated or properly documented. Many businesses create an SPCC plan but don’t update it when significant changes occur, such as facility expansion, equipment upgrades, or changes in oil storage capacity. The Environmental Protection Agency (EPA) requires that plans be reviewed and updated at least every five years or whenever a significant change occurs.

How to Avoid It:
Assign a team member or hire a consultant to conduct regular reviews of your SPCC plan. Create a schedule for inspections and updates, and document any changes made to your facility to ensure compliance with the EPA’s requirements.

2. Improper Secondary Containment

Secondary containment is a critical component of an SPCC plan. This involves providing barriers, like walls, dikes, or berms, that can contain a spill and prevent oil from reaching navigable waters. Many violations occur when facilities fail to install proper containment measures or when the containment structures are not adequately maintained.

How to Avoid It:
Ensure that all oil storage areas have appropriate secondary containment structures that meet EPA standards. Regularly inspect these structures for cracks, wear, or damage and repair them promptly to avoid violations.

3. Failure to Conduct Regular Inspections

The EPA requires facilities with an SPCC plan to perform regular (monthly) inspections and testing of oil storage containers, piping, and other equipment. Failing to conduct these inspections or keep proper records is a common violation.

How to Avoid It:
Develop a detailed inspection schedule that covers all oil storage and handling equipment. Keep thorough records of each inspection, noting any issues and repairs made. These records should be readily available during audits or inspections by regulatory authorities.

4. Inadequate Employee Training

Your SPCC plan is only as effective as the people implementing it. Many facilities violate SPCC regulations by failing to provide adequate training for employees on how to prevent and respond to oil spills. Without proper training, employees may not know how to execute the SPCC plan in an emergency.

How to Avoid It:
Take our online SPCC training for all employees involved in oil storage, handling, or response. Alternatively, you can develop your own training program. Training should cover spill prevention procedures, containment measures, and emergency response protocols. Make sure training sessions are documented and occur regularly.

5. Failure to Conduct Annual Plan Reviews

SPCC plans require periodic review and must reflect current site conditions, including any changes in oil storage, handling, or infrastructure. Failing to conduct these reviews can lead to non-compliance, especially if the site changes significantly over time.

How to Avoid It:
Set a yearly reminder to review your SPCC plan in detail. During this review, assess whether any changes to the facility or operations require updates to the plan. Even if no significant changes have occurred, conducting an annual review demonstrates a proactive approach to compliance.

Conclusion: Don't Make These Mistakes!

Avoiding SPCC plan violations is crucial for protecting your facility from regulatory fines and ensuring environmental responsibility.

By keeping your SPCC plan up to date, providing proper training, and conducting regular inspections, you can avoid the most common violations and ensure your facility remains compliant with EPA regulations.

Need help developing or updating your SPCC plan? Contact us today for expert assistance!