When next to each other, the two dirtiest words in the EPA lexicon is “accidental spill.” So, if you’re in charge of a facility that produces, processes, and/or stores hazardous substances, the EPA is keeping a special eye on you. (Isn’t it nice to be important?) And what they want to see is that you’re identifying likely hazards related to an accidental spill.

More specifically, the EPA conducts reviews and inspections to assure that your facility is designed and maintained to minimize the likelihood (or consequences) of an accidental spill; and that you have a Risk Management Plan in the event of such a spill (cleverly referred to as an “RMP” in that afore mentioned EPA lexicon).

Know what you’re dealing with

We should digress here: if you’re unsure whether any of what you’re producing, processing, and/or storing is regarded as a “hazardous waste” by the EPA—or by one or another state or local authority—you so don’t want to find out after you have a few gallons of it accidentally oozing & bubbling on your shop floor and slithering into the nearest storm sewer.

In other words, get expert advice. Ignorance of the law won’t protect you from possible criminal charges; and the best you might hope for in such ugly circumstances is a “low-security” federal accommodation, possibly one with tennis courts, if you’re lucky.

Better safe than sorry

Our technicians can accurately conduct an onsite analysis to identify and quantify both the “listed” and “characteristic” substances that might be produced, processed, and/or stored in your facility. And accuracy is paramount, because the EPA doesn’t see much difference between waste “mischaracterization” and no “characterization” at all. They’re funny that way.

Risk Management Plan (RMP)

Your RMP should minimally contain these elements:

  • Spill response team. You need to identify people who are authorized to deal with an accidental spill, trained to recognize the kind of danger it presents, and who know how to safely clean it up. Spill-team members also must be able to determine (quickly!) whether the spill is “incidental” (i.e. small) vs. “emergency” (i.e. large).
  • Emergency guide. This is a list of essential phone numbers and “what to do” assignments in the event of one or another kind of spill, which all employees need to read and understand.
  • Spill kit. This should contain (for example) absorbents, solvents, and corrosive spill pads for the kinds of “listed” and/or “characteristic” hazardous substances you produce, process, or store. It should also contain plastic bags and/or collection containers for holding the spill; labels for identifying it; and appropriate protective gear like gloves, coats, goggles, etc. for your spill team.

Small incidental spills

Incidental spills involving small quantities of lower-hazard chemicals are most common. By definition, these don’t pose a substantial hazard to employees or your spill team, and so no out of town talent is necessary to clean things up safely & legally. You can do it yourself.

In a typical scenario, your spill team will first evacuate people in the immediate area to avoid their breathing vapors or otherwise coming into contact with the spill; and then they’ll determine what exactly has been spilled.

Your spill team will confine the spill to the smallest possible area, of course wearing safety goggles, gloves, and the other protective gear contained in your spill kit.

Saturated absorbent should be placed in a plastic bag or other appropriate container, properly labeled as hazardous waste, and disposed of according to your existing hazardous-waste management protocol—assuming you have one…and you had better. Again, expert advice is crucial.

Lastly, the contaminated area should be thoroughly flushed with water, and your spill-kit materials replenished for the next small accidental spill—God forbid.

Large “emergency” spills

What’s Large? Unfortunately, there’s no standard per the EPA. The distinction must be made by you at your facility, ad hoc, based on training and other factors.

So here, instead, we invoke our friends at OSHA, where the people in charge of acronyms are much more creative. As evidence, we present HAZWOPER, which while sounding like a toxic ethnic joke, actually stands for Hazardous Waste Operations and Emergency Response, at least if you scrunch up your eyes and look through your lashes.

HAZWOPER is a set of OSHA guidelines that regulate hazardous waste operations and emergency services. In part, they stipulate that “the quantity of product spilled does not by itself determine if an incidental spill has occurred.” Instead, several variables must be considered, like what was spilled and whence it was spilt.

Are you big enough to handle large spills?

For your spill team to handle large spills legally, they must each have 8-to-40 hours of initial training and endure annual refresher courses. Obviously, such requirements are burdensome for small-to-medium enterprises that produce, process, and/or store smaller amounts of hazardous materials, so that the case for outside help is pretty obvious.

The upshot

As we’ve blogged about before, you need to establish a relationship with a company that specializes in emergency spill response—before a large accidental spill happens. Look for companies that have a documented history of fast response times. (The best of these will usually be onsite in about two hours.)

They should also be expert in the analyses department. If your spill involves an unknown chemical or substance, you want them to be able to figure out what it is—quickly & completely—so they can remove it the same way: quickly & completely…and per the law.

You need expert advice, and you can learn about the best accidental spill-response services in your area by clicking here or by calling PegEx at (800) 936-2311.

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