Spill response planning

When a spill happens, there is no time to work out who should do what, where the spill kit is, which drain leads to the creek or which number to call. Those decisions have to be made in advance and written down in a spill response plan. A good plan is short enough to use under pressure, specific to the site, and known to everyone who works there. This lesson explains what a plan contains, which laws require formal plans, and how to keep a plan alive through training and drills.

Why a written plan

Spill response depends on speed and on doing things in the right order. In the first few minutes, people need to protect themselves, stop the source if they safely can, stop the spill from reaching drains and water, and call the right people. A written plan sets out that sequence, assigns roles, lists the equipment and where it is, and gives the phone numbers. It also shows regulators and courts that the employer took reasonable care. A plan that sits in a binder in an office that nobody visits does none of this. The plan must be used in training, practiced in drills and posted where spills are likely.

What the plan contains

Plans vary in length and format, but most contain the same core elements. The table below lists them. Small sites may combine them into a few pages; large sites with many hazardous substances need more detail and often separate procedures for each major hazard.

Defining spill sizes and response levels

Most plans classify spills into levels so that people know what they can handle and when to escalate. A typical scheme has three levels. A minor or incidental spill is small, of a known substance, contained on a surface without a pathway to drains or water, and safe to clean up with a local spill kit by trained workers wearing standard protective equipment. A moderate spill is larger or reaches soil or a drain, needs the site response team and more equipment, and usually must be reported. A major spill threatens people or the environment beyond the site, involves a hazardous substance that workers are not equipped to handle, or is too large to control, and needs evacuation and outside emergency responders.

The levels should match OSHA's distinction between incidental releases and emergency response. A level 1 spill is usually incidental and can be handled by trained workers in the area. Anything that requires an emergency response under HAZWOPER must be handled by responders trained to the appropriate level, and the employer's emergency response plan must say who they are.

Roles

Every plan needs clear roles, with named people and backups for every shift. The person who discovers a spill must know what to do first and whom to tell. A spill coordinator or incident commander takes charge, decides on the response level and directs the response. Someone calls emergency services and regulators. Someone meets responders at the gate and briefs them. Someone keeps a log of times, actions and decisions. On small sites one person may fill several roles; on large sites the roles follow the incident command system used by emergency services.

Formal plans required by law

Some sites must prepare formal plans under specific regulations. Facilities subject to the Spill Prevention, Control, and Countermeasure rule must prepare an SPCC plan. The rule applies to non-transportation facilities that could reasonably be expected to discharge oil to navigable waters or adjoining shorelines and have more than 1,320 US gallons of aboveground oil storage capacity (counting only containers of 55 gallons or more) or more than 42,000 gallons of completely buried capacity. A professional engineer must certify the plan, except that smaller qualified facilities may self-certify, and the plan must be reviewed at least every five years. Facilities that could cause substantial harm, such as large oil terminals, must also prepare a facility response plan under the Oil Pollution Act. Facilities with large quantities of certain chemicals may need a Clean Air Act risk management plan, and EPCRA requires reporting of hazardous chemical inventories. OSHA requires emergency action plans and, where employees respond to releases, an emergency response plan under HAZWOPER.

# SPCC applicability check (US): count aboveground containers of 55 gallons or more.
containers_gal = {"diesel tank": 1000, "gasoline tank": 300, "hydraulic drum 1": 55,
                  "hydraulic drum 2": 55, "hydraulic drum 3": 55, "hydraulic drum 4": 55,
                  "5-gal oil cans x 6": 30}
counted = {k: v for k, v in containers_gal.items() if v >= 55}
total = sum(counted.values())
print("Counted containers:", ", ".join(counted))
print(f"Aboveground capacity counted: {total:,} gal (threshold 1,320 gal)")
print("Above threshold" if total > 1320 else "Below threshold")
print(f"That is about {total * 3.785:,.0f} L")

Counted containers: diesel tank, gasoline tank, hydraulic drum 1, hydraulic drum 2, hydraulic drum 3, hydraulic drum 4
Aboveground capacity counted: 1,520 gal (threshold 1,320 gal)
Above threshold
That is about 5,753 L

Notification lists

The notification list is the part of the plan used most under pressure, so it must be accurate and easy to read. It should start with emergency services, then the internal spill coordinator and managers, then regulators with their numbers and what triggers a call, then the sewer authority or municipality, then spill contractors, and finally neighbors or downstream water users who must be warned. Numbers must be checked regularly, because people change jobs and agencies change numbers. Many sites post a laminated card at each spill kit with the first few calls to make.

For US sites the list typically includes 911 for fire, injury or immediate danger, the National Response Center at 1-800-424-8802, the state spill line, the state emergency response commission and local emergency planning committee where EPCRA applies, the sewer authority for spills to sewers, and CHEMTREC for chemical advice. Lesson 11 covers reporting in detail.

Training and drills

People do not remember a plan they have only read once. Everyone who works where spills could happen should be trained on the plan when they start, when it changes and at regular intervals, often yearly. Training should cover recognizing a spill, the first actions, the site's spill levels, where the kits are and how to use them, whom to call, and personal safety. Supervisors and spill team members need more detail.

Drills test whether the plan works. A tabletop exercise walks through a scenario around a table, testing decisions and communication. A functional drill has people actually deploy spill kits, cover drains and make practice calls. A full-scale exercise may involve outside responders. Each drill should end with a short review of what worked, what did not and what will change, and the changes should be made. Drills often reveal practical problems: an empty spill kit, a locked gate, a phone number that no longer works, drain covers that do not fit the drains.

Keeping the plan current

Plans go out of date when the site changes. New tanks, different chemicals, new buildings, changes to drains, new staff and new phone numbers all need updating. Most plans should be reviewed at least yearly and after every significant spill or drill, and formal plans have their own review requirements. Each version should show its date and what changed. Old copies should be removed from circulation so that nobody follows outdated instructions.