Do I need an SPCC Plan for Cooking Oil or Used Cooking Oil?

Wait, Cooking Oil Can Trigger SPCC Requirements? Everything You Need to Know!

If you’re handling quantities of cooking oil, whether it’s fresh or used, you may be wondering if an SPCC plan applies to your facility. After all, cooking oil doesn’t feel like a “hazardous” material in the way diesel fuel or industrial chemicals do. But from the EPA’s perspective, new or used, oil is oil.

So the short answer is yes, cooking oil does trigger SPCC requirements. And that can come as a surprise to all sorts of businesses dealing with cooking oil who’ve never had to think about environmental regulations like spill prevention rules before.

In this article, we’ll break down exactly when cooking oil is regulated under SPCC, who’s affected, and what your options are if you need a plan.

If you're here because you're already being asked for one - by a fire marshal, an inspector, or even your landlord - you're not alone. Reach out to talk to an SPCC expert about your options.

Table of Contents

• What is an SPCC Plan?
• Do I need an SPCC plan for cooking oil or used cooking oil?
• What type of cooking oil businesses usually need (and don't need) an SPCC plan?
• How do I get an SPCC plan?
• How much does an SPCC plan cost?
• Can you get an SPCC plan online?
• How long does it take to get an SPCC plan?
• What kinds of cooking oils are included under SPCC rules?
• What happens if I don't get an SPCC plan?
• Additional SPCC Plan Information

What is an SPCC Plan?

Okay, let’s start with the basics. An SPCC Plan (Spill Prevention, Control, and Countermeasure Plan) is an EPA-required document (stemming from the Federal Clean Water Act) designed to prevent oil spills from reaching "navigable waters or shorelines".

But what is it really? It's a physical document (like a binder or book) that describes your specific facility, the oils you have, where & how they're stored, how you prevent spills, and what you'll do if a spill occurs. Each one is unique, and it's basically your personalized playbook for all things oil.

It applies to all kinds of facilities that store, use, or handle oil (and yes, that includes new and used cooking oil) in quantities above certain thresholds. 

Think of an SPCC plan like an environmental insurance policy. It’s a mix of documentation, site practices, and safeguards that show you’ve thought ahead and taken action to prevent a costly mess (and how to respond if an accident does occur). For a full deep-dive, check out the video below.

Do I need an SPCC plan for cooking oil or used cooking oil?

Maybe. It depends on three key factors, and one in particular matters most.

To figure out whether you need an SPCC plan for your cooking oil, you’ll need to run through this checklist. If all three apply to your site, then yes - the EPA requires you to have an SPCC plan in place. Here’s what they’re looking for:

1. You store more than 1,320 gallons of oil above ground.

This is the big one! It’s not about how much oil you use in a year or how often your used oil gets picked up. The EPA is looking strictly at your total on-site storage capacity at any given time. That means all your containers that could hold oil - as long as they’re 55 gallons or larger - count toward that total.

Got four 275-gallon tote tanks of used cooking oil behind the building? That's 1,100 gallons right there! Add in a few drums, and boom, you’re over the threshold. Smaller containers (under 55 gallons) don’t count toward the total, but for drums, totes, and aboveground storage tanks (containers) it adds up faster than you might think.

2. You’re not in the transportation industry.

This one gets murky. The rule is meant to exclude facilities where transporting oil is the core function (like pipelines, tanker trucks, or railroads). If your business is producing oil, using it, collecting it - even if that means transporting it at some point - then you're still probably on the hook for SPCC. Unless you're regulated as a transporter by DOT, assume SPCC applies to you.

3. There’s a reasonable expectation of discharge to navigable waters.

This one sounds like it could be a loophole... but it’s not. I know what you're thinking, but sorry, it's not clever, the EPA has heard it for years, and they don't buy it.

In the real world, if your site has storm drains, floor drains, or any drainage features that could eventually reach a waterway, the EPA considers you to have this “reasonable expectation.” And in our experience, pretty much every site does. So unless you’re storing oil in a vault in the middle of the desert inside of a quarry with zero drains, assume this box is checked.

So, what’s the bottom line with SPCC thresholds?

If you have more than 1,320 gallons of cooking oil or used cooking oil stored in containers 55 gallons or larger, then SPCC most likely applies, and you need to get serious about getting a plan in place.

The other two factors? They matter, but they’re rarely your out. That 1,320-gallon threshold is the make-or-break. If you’re not sure how close you are to the limit, just reach out and we’ll run the numbers with you.

What Types of Businesses Need an SPCC Plan for Cooking Oil?

To figure out who’s affected by SPCC rules, it helps to think about the life cycle of cooking oil, from production to use to disposal (and even reuse!) and what kind of storage happens at each stage.

And remember: This isn’t just about cooking oil. The EPA’s rule applies to any oil, including fuels, hydraulic oil, lubricants, animal fats, and more. Animal, mineral, plant, synthetic, whatever, oil is oil. So if you’ve got other types of oil on site too (in containers 55 gallons and up), you’ll need to count them toward your total. Let’s break it down:

🏭 Oil Producers & Processing Facilities

If you're pressing olives, rendering animal fat, or otherwise producing or processing oils, you almost definitely cross the 1,320-gallon threshold.

These sites tend to have large tanks of cooking oil, along with all the regular tanks and drums and totes used to store oil as part of your facility processes. You may have a few thousand gallons of cooking oil in tanks waiting to be shipped off - along with some 55-gallon drums of hydraulic fluid used for maintenance, maybe an underground storage tank of diesel for fueling trucks... Point being, all oil gets included, and in larger, industrial operations that produce something, it's almost a guarantee there's a couple extra containers of oil sitting around. This all means you'll need a written plan, secondary containment, and regular inspections - you need an SPCC Plan for that cooking oil, and everything else oil related!

📦 Storage & Warehousing Operations

If you're storing large volumes of cooking oil or used cooking oil before it’s shipped to a processor or customer, you’re likely in the realm of SPCC considerations as well. This includes facilities that warehouse oil in drums, totes, or tanks. If those containers are 55 gallons or more and your total storage adds up, you need a plan.

🥫 Food Production & Processing Facilities

Running large fryers, pressure cookers, or production lines that use cooking oil in your recipes? Maybe you're manufacturing cereal, or dog food, or some new snack that hasn't hit the market yet! You're likely storing oil in bulk to use as part of the food production process, and you are probably sitting on more than 1,320 gallons.

We see this a lot in large-scale operations that produce goods that end up in grocery stores. Even if you’re using it and recycling it in-house, the storage capacity is all that matters - over the 1,320 gallon threshold and you need an SPCC plan.

🍔 Standard Restaurants

Most restaurants that you'd consider for breakfast, lunch, or dinner are usually in the clear. Typical deep fryers and small waste containers often keep you well below the SPCC threshold. That said, don’t just assume! If you’ve got multiple used cooking oil containers out back take a minute to run the numbers. A couple of those nasty, grease coated, used cooking oil filled black-tanks sitting outside your restaurant could bring you closer to the realm of SPCC needs than you think.

🎢 Large-Scale Food Service Operations

Amusement parks, stadiums, airports, casinos, and universities - these are the wildcards. You might not think of yourselves as oil-handling facilities, but with food courts, vendors, and multiple kitchens, the combined total of fresh and used oil containers could tip the scale.

Now, are each of these kitchens going to be regulated separately, or will they all be lumped together under your theme park? The answer here is complicated, and probably not one you want to risk - you’ll want to do an inventory. Think storage tanks, and collection bins across all locations. If you're over the limit, it's time to dig a little deeper.

🔁 Used Oil Processors & Recyclers

If you collect and consolidate waste cooking oil, whether you call it UCO, used cooking oil, waste vegetable oil, whatever - for resale, disposal, or recycling - just like everyone else, your SPCC status depends on how much you’re holding at once. Some setups run lean and stay under the limit. Others consolidate at a yard or warehouse and exceed it easily.

If you’ve got multiple totes, tanks, or a staging area, you’re probably in. And keep in mind, even temporary storage counts. If you're only holding oil for just a few days at a time before pickup or processing, it still adds to your total, and still counts under SPCC.

🔬 Used Cooking Oil Refiners

Turning used oil into biodiesel? Making soap, animal feed, or other industrial inputs? You’re refining a regulated material, and almost certainly doing it in bulk. That means you’re most likely going to be subject to SPCC, and possibly other regulations too. If you’re not already operating with a plan, containment, and regular inspections, now’s the time to fix that.

The cooking oil (and used cooking oil) SPCC takeaway?

If you’re not sure where you fall, the best first step is to take a quick inventory of every oil container 55 gallons or larger. Tally up the total storage capacity, and if it’s over 1,320 gallons, you need to start building your SPCC plan. More on that next.

How Do I Get an SPCC Plan for Cooking Oil?

There are three types of SPCC plans, and the kind you need depends on how much oil you store, and the size of your largest containers. The EPA allows some facilities to write and certify their own plans, while others need a licensed engineer involved. Here’s how it breaks down:

Tier I – Self-Certified Plan

If your facility has:

• Less than 10,000 gallons of total oil storage, and
• No single oil container larger than 5,000 gallons...

then you qualify for a Tier I SPCC Plan. These are the simplest type of plan, and the EPA even offers a free template you can fill out and certify yourself. But a word of caution: if your self-prepared plan is missing information or isn’t considered adequate during an inspection (or worse - a spill), you can still face penalties. Many facilities in this category still choose to work with a professional to make sure it’s done right.

Tier II – Self-Certified Plan

If you have:

• Less than 10,000 gallons total storage, but
• One or more oil containers are over 5,000 gallons...

then you fall into Tier II. You’re still allowed to self-certify the plan, but the requirements are more detailed. The EPA expects a more thorough document, and the risk of missing something goes up. At this level, most businesses choose to have a professional develop the plan to ensure everything is compliant.

Full PE-Certified Plan

If your facility has:

• More than 10,000 gallons of oil storage in total, or
• A history of spills or regulatory violations...

then your plan must be certified by a licensed Professional Engineer (PE). These plans require a more technical approach and involve a detailed review of your facility’s layout, containment, spill response procedures, and inspection protocols. This isn’t something you can do in-house (unless you're an engineer). It needs to be developed by professionals and signed off by a qualified engineer.

Need help figuring it out?

We work with businesses handling cooking oil every week who aren’t sure which category they fall into. SPCC plans are a core part of what we do, and we’re happy to help you sort it out - whether you need a full PE-certified plan or just a second opinion on a self-certified draft. Contact us here if you want help reviewing your options or building your plan.

How Much Does an SPCC Plan Cost at a Cooking Oil (or Used Cooking Oil) Facility?

Like most environmental compliance work, the answer is: it depends. But we can give you some realistic ballpark numbers so you’re not flying blind.

The cost of an SPCC plan depends on several factors, including:

• The total amount of oil you store
• The type of plan you need (Tier I, Tier II, or PE-certified)
• The complexity of your site
• Whether a site visit is required
• How quickly you need it

Typical Cost Ranges

• Tier I (Self-Certified): $2,000–$4,500+
  If you’re eligible for a Tier I plan and want professional help preparing it, this is usually the most affordable option. Some facilities choose to do it themselves, but many bring in help to make sure it’s done right.
• Tier II (Self-Certified with Larger Tanks): $3,000–$5,000+
  The documentation requirements increase at this level, especially around containment and inspection procedures. Many companies prefer to have a professional handle it.
• Full PE-Certified Plan: $5,000–$10,000+
  These are the most comprehensive plans, often for larger or more complex facilities. They require engineering review, custom layouts, and documentation that meets the EPA’s stricter standards.

Can You Get an SPCC Plan Online, Without a Site Visit?

In some cases, yes. If your facility is straightforward, say, a few tanks or totes, good site photos, and a clear layout, you might qualify for a remotely developed SPCC plan. This can save time and lower the overall cost.

That said, some sites do require an in-person visit, especially if the layout is complicated, there are questions about containment, or you're dealing with a PE-certified plan. If you're not sure which category you're in, we can help you figure it out in about 10 minutes. Just get in touch here and we’ll walk you through it.

How Long Does It Take to Get an SPCC Plan?

The timeline depends on two things:

1. How complex your facility is
2. How you’re going about getting your plan done

If you’re preparing the plan yourself, the timing is entirely up to you. But keep in mind: even with a template, it takes time to gather the right information, document everything properly, and make sure the plan actually meets the EPA’s requirements.

If you’re hiring a professional, the turnaround time will depend on their schedule, whether a site visit is required, and how complex your operation is.

General Timeframes

• Simple facility, remote plan: About 2–3 weeks
  If you qualify for a remotely developed plan, and can provide clear site details and photos, this is usually the fastest option.
• Simple facility, on-site plan: Around one month
  For smaller sites that still need a site visit, the process usually takes about a month from kickoff to final delivery.
• Complex facility, PE-certified plan: A month or two
  If your site is larger, has many oil sources, or requires a PE-certified plan, expect a longer timeline. These plans require more documentation and internal review.

Keep in mind: if you’re on a tight deadline (for example, if you’ve been asked for a plan by your landlord, an inspector, or a regulator), we can often expedite depending on the situation. Just let us know what you’re up against.

What Kinds of Cooking Oils Are Included In an SPCC Plan?

If you're storing or handling any kind of cooking oil, it’s likely covered under the SPCC rule. The EPA doesn't distinguish between petroleum-based oils and food-grade oils, they all count.

Here are the most common types of cooking oils that fall under SPCC:

• Vegetable oils like:
  • Soybean oil
  • Corn oil
  • Canola oil
  • Sunflower oil
  • Palm oil
  • Cottonseed oil
  • Safflower oil
  • Olive oil
  • Avocado oil
• Animal fats such as:
  • Tallow (beef fat)
  • Lard (pork fat)
  • Poultry fat
  • Fish oil
  • Butterfat (in bulk storage)
• Used cooking oil (UCO) and fryer oil from food service operations
• Blended or specialty oils, including flavored oils or margarine in liquid form
• Waste oils from food processing or oil recycling operations

If you’re storing these in bulk, especially in drums, totes, or tanks, they contribute to your facility’s total oil storage under SPCC.

Other Oils That Count Toward Your SPCC Threshold

SPCC isn’t just about cooking oils. The rule applies to any oil of any kind, as long as it's stored in containers 55-gallons and up. That means you also need to count:

• Diesel, fuel oil, or gasoline
• Hydraulic oil used in equipment or presses
• Lubricants and greases used for maintenance
• Mineral oils, compressor oils, or transmission fluids
• Any synthetic or petroleum-based oil products

If it’s an oil and you’re storing it in a container 55 gallons or larger, it belongs in your SPCC storage total - no matter what type it is or how it's used.

What Happens If I Don’t Get an SPCC Plan?

Well... maybe nothing. Some facilities skate by for years without a problem. It’s a bit like driving without a license. If no one pulls you over and you never get in an accident, you’re fine. But if you do get pulled over (or worse, cause an accident) suddenly it matters a lot. That’s how it works with SPCC plans. If you get inspected or have a spill and don’t have a required plan in place, it becomes a serious issue, fast.

Inspections can happen at any time. Even if no one’s ever shown up before, someone from the EPA, your state agency, or even the local fire department could stop by tomorrow and ask to see your plan. If you’re required to have one and don’t, the penalties are steep. The EPA can issue fines of up to $68,445 per violation, per day, which yes, is generally reserved for the most extreme cases. That means a few weeks of non-compliance could lead to hundreds of thousands or even millions of dollars in fines, and that's before you factor in legal fees, consulting fees, clean up costs if you had a spill, business disruption, and even brand reputation hits.

But the bigger risk is a spill. If cooking oil from your site enters a storm drain or waterway and you didn’t have a plan in place, you’ll be held fully responsible. That can mean regulatory enforcement, environmental cleanup, reputational damage, and a whole lot of questions from customers and insurers. In some cases, it can put a company out of business. Moral of the story: the cost of non-compliance is more than just fines!

So yes, sometimes people get lucky. But when things go wrong, they go wrong fast, and the cost of not having a plan can be far greater than just doing it right in the first place.

Where to Go for More SPCC Information on Cooking Oil

At RMA, we’ve been helping businesses stay compliant with SPCC regulations since 1992, and we've assisted with more SPCC plans than we can count. You could say it's our bread and butter... er, oil?

Bottom line: if you need an SPCC plan for cooking oil (or used cooking oil), we've got you covered - whether you're producing it, storing it, using it, or refining it. We’ve worked with facilities across the country in many stages of the cooking oil lifecycle, and we understand the unique compliance challenges your industry faces.

If you’re looking for a deeper dive into SPCC plans in general, including what goes into a plan, how inspections work, and what to expect - check out this full guide to SPCC plans. It walks through the details more thoroughly and answers common questions we hear from clients.

And if you’re ready to talk through your specific situation or just want to know if SPCC applies to you, reach out to us here. We’ll help you understand what you need, what it’ll take, and how to get it done with confidence.