Every Option Compared: Self-Certifying, EPA's Template, Professional Engineers, Consultants, and Online Services
If your facility stores oil above ground in New Jersey, you may need a Spill Prevention, Control, and Countermeasure Plan, usually shortened to SPCC Plan. It's the federal oil spill plan required by 40 CFR Part 112, and in New Jersey it's enforced by EPA Region 2. Most facility managers figure out they need one without much trouble. The harder question is who's allowed to write it and who has to sign off on it, because the rule treats those as two separate jobs and the answer changes with your storage volume, your largest container, and your spill history.
The short answer is that anyone can write an SPCC Plan, but only certain people can certify it. Facilities with 10,000 gallons or less of total aboveground oil storage and a clean spill history can self-certify, and everyone else needs a licensed Professional Engineer (PE) to review and certify the plan. Below we compare every realistic option side by side, including doing it yourself, using EPA's template, hiring an independent PE or an engineering firm, working with an environmental consultant like RMA, and buying a plan online. If you'd rather talk through your own facility, feel free to reach out to RMA and we'll tell you which path fits, even when the answer is that you don't need us.
Table of Contents
TL;DR
Anyone can write an SPCC Plan, but only certain people can certify it. A facility with 10,000 gallons or less of total aboveground oil storage and a clean spill history can self-certify, and every other facility needs a licensed Professional Engineer to review and certify the plan. Your realistic options are doing it yourself with EPA's template, hiring an independent engineer or an engineering firm, working with an environmental consultant, or using an online service, and the right one depends on your storage, your spill history, and how much of the work you want to handle. In New Jersey, a major facility's DPCC plan also needs certification from a New Jersey-licensed PE.
Who Is Allowed to Write an SPCC Plan, and Who Has to Certify It?
Writing and certifying are two different jobs under the SPCC rule. Anyone can write the plan. Your own staff can do it, a consultant can do it, an engineer can do it, and EPA's template can walk you through it. Nothing in 40 CFR Part 112 requires a license to prepare the document itself.
Certification is where the rules are. Under 40 CFR 112.3(d), a licensed Professional Engineer (PE) must review and certify a plan for it to be effective, with one exception: qualified facilities under 112.6 can self-certify. A well-written plan that skipped a required PE certification still falls short, which is an easy mistake with a plan written in-house or bought online for a facility that was never eligible to self-certify. Certification also doesn't transfer your responsibilities. The inspections, training, containment upkeep, and spill response stay with your facility, so look at what you're left with after the signature, not just who signs.
Which New Jersey Facilities Can Self-Certify an SPCC Plan?
EPA created the qualified facility category so smaller facilities don't need a PE. A qualified facility has 10,000 gallons or less of total aboveground oil storage capacity and a clean spill record. Under 40 CFR 112.3(g), you fail the spill test if, in the three years before you self-certify, you had a single discharge over 1,000 gallons or two discharges each over 42 gallons within any twelve-month period. Capacity means what your containers can hold, not what's in them today, and it counts containers of 55 gallons or more, including oil-filled equipment. Add everything up before you decide you qualify.
| Category |
Storage limits |
Who certifies |
What to know |
| Tier I qualified facility |
10,000 gallons or less in total, no single container over 5,000 gallons, clean spill history |
The owner or operator self-certifies |
EPA's Appendix G template can serve as the plan. No deviations from the rule are allowed. |
| Tier II qualified facility |
10,000 gallons or less in total, any container size, clean spill history |
The owner self-certifies, but a licensed PE must certify any alternative measures |
You write a full plan under the general rule. A PE certifies any environmental equivalence method or secondary containment impracticability determination. |
| Not a qualified facility |
Over 10,000 gallons in total, or a disqualifying spill history |
A licensed PE reviews and certifies the whole plan |
This covers most industrial sites, including concrete plants, manufacturers, data centers with generator fuel storage, and fleet yards. |
A note on terms: "Tier II" in the SPCC rule describes a type of qualified facility. New Jersey facilities also hear "Tier II" in connection with Community Right to Know chemical inventory reporting, which is a separate program that has nothing to do with who certifies your oil spill plan.
When you self-certify, you're signing a statement that you visited and examined the facility, that the plan follows sound industry practice, that inspection procedures are in place, that you'll fully implement the plan, and that management has approved it and committed the resources. If a facility outgrows 10,000 gallons, the rule gives you six months to move to a PE-certified plan. EPA also notes that some states don't allow self-certification, so confirm with NJDEP before you rely on it. Our guides to the Tier I self-certified plan and the Tier II self-certified plan go deeper.
When Does a Professional Engineer Have to Certify an SPCC Plan?
Any facility that isn't a qualified facility needs a licensed PE to review and certify the plan. Under 40 CFR 112.3(d)(1), the PE attests to being familiar with Part 112, that the PE or an agent visited and examined the facility, that the plan follows good engineering practice including applicable industry standards, that inspection and testing procedures are established, and that the plan is adequate for the facility.
EPA allows an agent of the PE to make the site visit if it's consistent with good engineering practice, but if the PE's judgment calls for a personal visit, the PE has to go. On licensing, the SPCC rule doesn't require the PE to be licensed in the facility's state, but EPA points out that state law may stop a PE from applying a seal where they aren't licensed. For a New Jersey facility, a New Jersey-licensed PE avoids the question. See our guide to professional engineers and SPCC plan requirements for more.
How Do the SPCC Plan Options Compare Side by Side?
Every option below can produce a compliant plan for the right facility, and every one can fail for the wrong one.
| Option |
Who writes and certifies |
Good at |
Limits |
Best fit |
| Your own team (Tier I or Tier II) |
Your staff writes the plan, and the owner self-certifies. Tier II alternative measures need a PE. |
Lowest cost, and your people learn the plan. |
Only if you qualify. You carry the certification risk, and capacity and containment are easy to get wrong. |
Small facilities with a clean spill history and staff with time |
| EPA's template |
You complete the Appendix G template and sign as owner. |
Free, structured, written for non-engineers. |
Built for Tier I only, and it still requires sized containment and overfill prevention. |
Tier I facilities wanting a guided start |
| Independent PE |
A PE writes or reviews the plan and certifies it. |
Holds the license the rule asks for, and gives independent review. |
Some only certify. Some don't know your operations. The site visit takes scheduling. |
Facilities that wrote a plan but can't self-certify |
| Engineering firm |
Firm staff writes the plan and a firm PE certifies it. |
Design capacity for containment, foundations, and piping. |
Higher cost and a slower timeline. |
Large or complex sites needing engineered containment |
| Environmental consultant |
The consultant writes the plan. A licensed PE certifies when required, and qualified facilities self-certify. |
Plan, inspections, training, and reviews in one relationship. |
Firms differ. Some have a PE on staff and others work with a trusted outside PE. |
Facilities wanting the plan written and maintained by specialists |
| RMA |
We write the plan, and where a PE has to certify it, that review is part of the project. Qualified facilities can self-certify our plans. |
Senior staff do the work, with published pricing, remote or on-site development, and training afterward. |
Not the cheapest. We rebuild outdated plans instead of patching ones others wrote, and we skip construction-phase permits. |
Facilities wanting a plan we'll stand behind, and multi-site operations |
| Online plan service |
You answer a questionnaire and software generates the plan. Certification varies. |
Fast and simple for a basic Tier I setup. |
Most skip the site visit, output can be generic, and PE certification may cost extra. |
Simple Tier I facilities that check the output |
The options aren't mutually exclusive. Many facilities have a consultant write the plan and a separate PE certify it, and a lower price on one line usually means more work for your team elsewhere, such as measuring tanks or writing inspection procedures.
Can You Write Your Own SPCC Plan With EPA's Template?
Yes, if you're a Tier I qualified facility. The template in Appendix G of 40 CFR Part 112 was built for that group, and under 112.6(a)(3), when the owner or operator completes and signs it, it can serve as the plan. It's free, and filling it out forces you to walk the site and look at every container.
The template doesn't ask for less than the rule requires. You still need secondary containment for the entire capacity of your largest container plus room for precipitation, including mobile and portable containers, and an overfill prevention system or documented procedure for each container. The mistakes we'd watch for are undercounting capacity, forgetting portable containers, and sizing containment without allowing for rainfall.
If you have a handful of small tanks, a clean spill history, and someone willing to walk the site with a tape measure, doing this yourself is a reasonable call, and we'd rather tell you that than sell you a plan you don't need. Our four steps to figure out if you need an SPCC plan can help you confirm where you stand. Tier II and PE-certified plans don't have a template, so those facilities work from the rule text.
What Do Independent PEs and Engineering Firms Offer for SPCC Plans?
Independent Professional Engineers
An independent PE is the most direct route when you've already written a plan and your facility can't self-certify. The license is what the rule asks for, and an outside reviewer catches gaps your team has stopped seeing. The limits are practical: some PEs only certify, others don't know how your site runs day to day, and the certification covers the plan, not your implementation of it. EPA suggests asking whether the engineer knows the SPCC rules and how many plans he or she has certified. We'd add whether the PE or an agent will visit your site.
Engineering Firms
Engineering firms bring design capacity. If your site needs containment designed rather than evaluated, or tank foundations assessed, a firm can do that work and certify the plan in one engagement. The tradeoffs are cost and pace, and SPCC can be a small line item at a firm built around design projects. Ask who will write the plan and who will visit your site.
How Do Environmental Consultants, Including RMA, Handle SPCC Plans?
A consultant writes the plan and usually builds in what keeps it working: inspection forms, employee training, and reviews when your facility changes. Firms differ on certification. Some have a PE on staff, and others work with a trusted outside PE. Either way, a licensed PE has to certify the plan unless you qualify to self-certify, so ask each firm how that step is handled. Our write-up on what it's like to hire an SPCC plan consultant shows what the process looks like.
Here's where RMA fits. We're a family-run firm based in New Jersey, working since 1992 and serving clients nationwide, and senior staff do the work. Our published range for an SPCC Plan is $2,500 to $15,000, and the price moves with total storage capacity, the number and type of containers, whether secondary containment needs evaluating, and whether PE certification is needed. We develop plans remotely or on site, and we explain how remote SPCC development works so you know what to expect. Our post on what SPCC plans cost has more.
We're also clear about where we're not the right call. If you qualify as Tier I with a couple of small tanks, the free template may be all you need. We generally don't update plans written by someone else, because we only hand over plans we can stand behind, so an outdated plan usually gets rebuilt. If your site needs containment engineered, an engineering firm fits better. And we don't prepare construction-phase permits or approvals.
Are Online SPCC Plan Services a Safe Way to Get an SPCC Plan?
Online services range from questionnaire-based generators to consultant-led plans developed remotely. The first group can work for a simple Tier I setup. Most don't include a site visit, the output can be generic, and a plan built from your answers is only as accurate as your tank counts. If your facility isn't qualified, you still need a licensed PE to certify, and some services don't offer that or charge extra. Ask who reviews your answers, who certifies the plan, and what happens when your facility changes.
When you self-certify as a Tier I owner, you're stating that you visited and examined the facility, and no software can do that for you. AI-generated plans add a related risk, since a plan can read well and still contain wrong capacity math. We don't use AI for client deliverables, and we've written on whether AI can write an SPCC plan. Our posts on getting an SPCC plan online and whether online SPCC plans are legit cover what to check before you pay.
Does a New Jersey DPCC Plan Change Who Can Certify Your SPCC Plan?
Everything above covers the federal SPCC Plan. New Jersey adds a second layer for "major facilities" under the Discharges of Petroleum and Other Hazardous Substances rules at N.J.A.C. 7:1E, administered by NJDEP. A major facility prepares Discharge Prevention, Containment and Countermeasure (DPCC) and Discharge Cleanup and Removal (DCR) plans as a single document and submits it to NJDEP for approval. Whether you count as a major facility depends on your total storage capacity and what you store, so check N.J.A.C. 7:1E against your own inventory.
Self-certification doesn't apply to DPCC plans. Under N.J.A.C. 7:1E-4.11(e), a DPCC plan, renewal, or amendment for a change requiring sound engineering practice must include a certification from a PE licensed in New Jersey under N.J.S.A. 45:8-27 et seq. NJDEP proposed amendments to N.J.A.C. 7:1E in May 2024, so check the current rule text before you start a submission. EPA Region 2 enforces the federal rule in New Jersey, and we explain who enforces SPCC plans and SPCC plans in New Jersey on our blog.
How Do You Choose the Right SPCC Plan Option for Your Facility?
Start with the facts the rule uses: total aboveground oil storage, your largest container, and your spill history over the past three years. If you qualify and have staff with time, self-certifying with EPA's template is a fair choice. If you wrote a plan but can't self-certify, an independent PE can review it. If you need containment engineered, look at an engineering firm. If you want one team to own the plan, training, and reviews, or you run several sites, a consultant makes sense.
Cost is the next filter. We built an SPCC pricing calculator, below, so you can get a ballpark for having RMA handle your plan before you decide.
Timing and upkeep matter too. A new facility has to prepare and implement its SPCC Plan before it begins operations. If you're building or expanding, construction-phase permits and approvals are outside what RMA does, and your engineer or contractor is the right contact. The operating side is where we help: the SPCC Plan, a DPCC plan if you're a major facility, spill reporting procedures, inspections, and training, and our online training library covers the employee side. Plans also need a review every five years and an amendment when your facility changes, so pick a path you can maintain. We explain how five-year reviews work, and what to do with a plan that's more than five years old.
How Can RMA Help With Your New Jersey SPCC Plan?
You don't have to sort out which option fits on your own. If you tell us what you store, how many containers you have, and whether you've had any spills, we can tell you whether you qualify to self-certify, whether a PE has to be involved, and what the work would realistically cost. Sometimes the answer is that you can do it yourself, and we'll say so.
There's no obligation and no pressure. You can call us, send an email, or fill out the form on our website, and a member of our team will follow up. When you're ready, contact RMA and we'll take it from there.
