We harp about SPCC regulations and plans constantly, but honestly, not everyone needs one. Depending on a few different things, it's relatively easy to tell whether or not you need one at your operation. Our clients tend to operate all different types of facilities. From concrete plants, to RV repair centers, to commercial agriculture operations, there's one constant we constantly see get overlooked: SPCC Plans.
I know, I know. You're thinking "great, another regulation!?" I hear you loud and clear. There's plenty of regulations, more than enough to keep you on your toes constantly. However, this regulation is pretty quick and easy to get into compliance with, and there's not much to do with it once you have it. Not only that, but it provides information and tools to keep your staff and operation safe in case of an emergency.
4 Steps to Determine if You Need an SPCC Plan
So let's figure it out. Do you need an SPCC Plan? It's pretty simple:
Take an inventory of all the oil you have on-site - You need to take into account any container that's over 55-gallons. Include oil drums, above or below ground storage tanks, integrated tanks in machinery like crushers, generators, or mobile tanks. SPCC regulations only regulate oil containers over 55-gallons. Don't count antifreeze, DEF (diesel exhaust fluid), or anything that is not made with petroleum.
Determine your peak amount of oil - Consider 55-gallon drums, mobile tanks, or mobile generators. How many are usually on-site? How many are on-site when you're really busy, or taking delivery of drums, or storing mobile machinery or tanks? You need to consider the maximum amount of oil stored on site. If your plan says you only have ten 55-gallon drums on-site, and an inspector counts twelve drums, you're in big trouble. And remember, if you have a 2,000-gallon tank, and it's only half full, it's counted as a 2,000-gallon tank.
Identify empty or unused tanks - A lot of sites have empty tanks stored on-site, or tanks that aren't used anymore. Unless it's crystal clear, with supporting documentation and signage, that the tanks are empty and unused, they count as full tanks. If they're empty, get them off-site. If they're unused, mark them as "empty & unused"!
Another thing to consider is if you've ever had any oil spills on site. If you have, you may have to use a different plan, regardless of the amount of volume you have on-site. However, if you ever had a spill, part of the clean-up process was most likely to get a plan, so chances are you already have one.
That's about it! It's not too hard to figure out if you need one, but writing one is another story. If you're in the process of determining if you need a plan and need help, click here to contact us or give us a call at 609-693-8301 to discuss your needs today.
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