What are OSHA's guidelines around spill containment?
Spill containment regulations in the United States are not governed by a single institution, but are shared among OSHA, EPA, US Coast Guard, NIOSH, NIEHS, NOAA, and several other organizations. As such, employers and employees alike might be confused about who’s responsible for what.
OSHA's focus is naturally on the health and safety of the employees. As such, their guidelines for spill containment are geared to ensuring that the employees involved in spill containment are not exposed to hazardous substances that could cause chronic health effects, chemical burns, sensitization, and other effects on their health and safety.
OSHA's requirements are listed in CFR 1910.120. The main requirements under the standard are:
- Spill containment plan
- Spill containment training
- Safety equipment to respond to a spill
I'll summarize each in turn.
Spill Containment Plan
All organizations that might be involved in spill response have to develop a spill containment plan that satisfies OSHA standards. The standard requires that the containers used during containment and cleanup meet the OSHA and EPA standards. It does not, however, provide strict directions about what secondary containment should look like, only that it should satisfy the volume requirement.
At a minimum, the plan should cover:
- The nature and size of the potential spill
- Hazards posed by the spill to the employees, the public, and the environment
- Resources needed to prevent, contain, and control the spill
- Responsibilities in the event of the spill
- Training required for the first responders (employees responding to an emergency release should be certified in accordance to HAZWOPER standard 29 CFR 1910.120)
- How to properly dispose of the waste
Spill Containment Training
OSHA has created the HAZWOPER standard to help protect employees and determine strict training criteria for those who could be exposed to hazardous substances during an emergency response.
This standard states that the employee involved in emergency releases need to:
- Have appropriate training
- Be certified in accordance with HAZWOPER standard 29 CFR 1910.120
- Be able to recognize and control hazards specific to containment and clean up
- Take the appropriate actions to protect themselves during a response
OSHA regulates the equipment used for the prevention and containment of spills. The equipment can be divided into two categories: equipment used to respond to the spill and PPE.
The equipment used to respond to a spill includes traditional and proven methods such as diking and ditching or the use of diatomaceous earth. OSHA recognizes, however, that new and more effective products, like oil solidifying polymers, are can play an important role in our response efforts.
The PPE used in spill containment is often specialized, cumbersome, and can introduce additional hazards, such as heat stress, impaired vision and communication, and physical and psychological stress. It is important to choose the equipment that is just right for the situation, as both over- and under-protection can be hazardous.
Appropriate training should be provided to respondents so they can properly select, don, doff, and decontaminate their PPE. Also, as stated above, drills should be conducted with the safety materials and equipment used during emergencies to determine its efficiency and build confidence and capability in first responders.
OSHA provides additional guidelines for spill response and containment, such as Incident Command Systems (ICS) and medical surveillance programs, but these are more tailored to agencies and companies that frequently respond to spill containment and less to employers who might be involved in a once-in-a-lifetime response.
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