With the November 10th Spill Prevention Control and Countermeasure plan (SPCC) compliance deadline now clearly within sight, it’s time to button up your SPCC plan and make sure it is fully implemented.
Some questions you may want to consider as you put the final touches on your SPCC plan:
- If a state or federal inspector arrives and asks for a copy of your plan, can you and/or your employees access it quickly?
- Have you signed your SPCC plan?
- Have you implemented security measures?
- Do you have appropriate secondary containment in place?
- Are your emergency contacts up-to-date and appropriate?
- Do you have a drawing with facility layout and oil storage locations?
- Have you implemented an inspection and record keeping program?
- Do you have a plan to conduct your annual training for employees that handle oil?
Remember, you may be able to develop your own SPCC plan and self-certify your plan. Also, the SPCC Rules may not apply if a spill will not reach navigable waters. However, you must evaluate how the SPCC rules apply, or do not apply, to your farm.
It’s worth mentioning again that the SPCC rules fall under the Clean Water Act, which carries some very significant “enforcement teeth.”