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Toolbox Talk

Preventing Oil and Fuel Spills (SPCC)

Oil is the most common thing we spill on a job site: diesel, hydraulic fluid, gear oil, used oil, lubricants. The EPA's Spill Prevention, Control, and Countermeasure rule, 40 CFR Part 112, exists to keep that oil from reaching creeks, rivers, and shorelines.

You don't have to memorize the regulation. You do have to know your site has an SPCC plan if it stores enough oil, and you have to follow the storage and handling rules that plan sets.

When SPCC Applies

A site is covered by SPCC when three things are true: it's non-transportation-related, it has more than 1,320 gallons of aggregate aboveground oil storage capacity (or more than 42,000 gallons completely buried), and there's a reasonable chance oil could reach navigable waters. Containers under 55 gallons don't count toward that 1,320-gallon total.

If your site is covered, there's a written SPCC plan on site. Know who your plan coordinator is and where the plan lives.

Spill Prevention Habits

  • Store fuel and oil drums over secondary containment, away from drains, ditches, and slopes down to water.
  • Keep containers closed and labeled. A rag stuffed in a bung is not a closed container.
  • Inspect tanks, drums, and equipment for drips, weeping seals, and stains at the start of each shift.
  • Never overfill. Watch the gauge and stop before the top.
  • Stage drip pans and absorbents wherever you transfer oil.

The Sheen Rule

Under the Clean Water Act's Discharge of Oil regulation, 40 CFR Part 110, any oil discharge that causes a visible film or sheen on water, or leaves sludge or emulsion beneath the surface, is a reportable spill. A rainbow shine on a puddle draining to a ditch is not nothing. It's a federal reporting trigger. If you see a sheen on water, treat it as reportable and tell your supervisor immediately.

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