Spill Prevention, Control, and Countermeasure (SPCC) Plans: Five Year Review vs. Technical Amendments… What’s the difference?
Why it matters. Ensuring compliance with these regulations is crucial to maintaining a safe and environmentally conscious workplace for all. Don’t wait until you have an oil release to react. SPCC plans are meant to proactively prevent releases.
The big picture. A technical amendment to an existing Professional Engineer (PE)-Certified SPCC Plan is required anytime “there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in § 112.1(b).” The amendment must be implemented within six months of the change at the facility (or less, for some states). At least every 5 years, the original plan must be reviewed as described below.
What we’re saying. A SPCC Plan which was certified by a PE at inception does not need to be re-certified by a PE, as long as there were no technical changes to the facility as described above. The five-year review must include:
- A review of more effective, field-proven prevention and control technologies. Have there been changes to industry standards that could impact your current SPCC plan? Pay particular attention to equipment with a history of failure.
- Review the overall SPCC Plan, including spill response contact information, lists of oil storage containers, procedures, facility diagrams, etc.
- Review your spill history to identify the root cause of release(s) at your facility. (Your spill history should include documentation of reportable and non-reportable spills to aid in this continuous improvement process). Pay particular attention to recurring or similar incidents.
The bottom line: Don’t wait until a 5-year review is due to have your PE certify technical amendments resulting from a change to the facility. Initiate a technical amendment within 6 months of any modifications.
Aegis Environmental has extensive experience helping clients with technical amendments, as well as their five-year review. Please let us know if we can also help you!