The long sought after clarification/exemption of milk as a regulated oil under the Spill Prevention Control and Countermeasure (SPCC) Plan rules is remaining elusive. If the exemption is not granted, the number of dairy farms that will require an SPCC will likely grow exponentially.
According to a recent article in The Watertown Daily Times, “The U.S. Environmental Protection Agency has not completely backed away from a proposal that could treat milk spilled on farms as if it were oil — although officials say they are working on a way to avoid such a rule” http://www.watertowndailytimes.com/article/20110212/NEWS02/302129960.
The current deadline to develop and implement an SPCC (for those facilities in operation after August 16, 2002) is November 2011. See our previous blog entries regarding SPCCs, including our October 15, 2010 entry.