• Employers covered under HAZWOPER must develop and implement a written spill containment program.
• The spill containment program needs to address hazardous materials onsite and detail potential control and response measures for them.

Although the Occupational Safety and Health Administration (OSHA) does not define exactly what a “major spill” is, the agency does require any employers that have the potential for a major spill to develop and implement a written spill containment program. Elements of a spill containment program are covered below.

Potential spills and available controls

To develop an effective spill containment program, the employer must conduct an assessment of the hazardous substances onsite; operations; and how containers are stored, handled, and transported.

After a careful assessment of all substances and operations at the site, the employer should document all hazardous substances onsite; any activities with spill potential, with their spill types and locations; and what control measures are available in the event of a spill.

Possible control measures include, but are not limited to:

• Absorbent materials;
• Overpack drums;
• Dikes and berms;
• Inflatable containment (like “kiddie pools”); and
• Pumps, hoses, shovels, and other equipment.

When selecting control measures, the employer must consider the largest possible spill that could occur. It should be noted that the site may be required to provide secondary containment in line with Environmental Protection Agency (EPA) regulations. These structures may require containment systems that:

• Have a “sufficiently impervious” base to contain leaks, spills, and accumulated precipitation until the material is detected and removed;
• Have a base that slopes or drains unless containers are elevated or protected from contact with accumulated liquids;
• Have sufficient capacity for 10 percent of the total volume of all containers in a containment system, or 100 percent of the volume of the largest container, whichever is greater;
• Have sufficient excess capacity to contain any run-on (such as rainwater, leachate, or other liquid that drains over the land), or otherwise prevent run-on from running into the containment system; and
• Remove any spilled or leaked waste or accumulated precipitation from the containment area in a timely manner to prevent overflow of the system.

Federal, state, and local secondary containment provisions that apply to a cleanup site may be more stringent.

Initial spill notification and response

The second element of the spill containment program must address who to call if a spill should occur, what information to provide during notification, and what response is expected, including when to activate the emergency response plan (ERP).

Site personnel should become familiar with their site’s spill containment program for specifics. However, upon discovery of a spill, this element of the program can provide instructions for:

• Summoning help;
• Alerting nearby personnel;
• Moving to a safe location;
• Contacting emergency medical services, if needed; and
• Keeping unauthorized personnel away from the spill.

Different employees may have different roles in the event of an emergency, depending on their level of training. All employees should know what their role is and what is expected of them should a spill occur.

Spill evaluation and response

The directives in the third spill containment program element include evaluating the spill and determining what type of response is needed to handle it. An authorized individual should identify the hazards associated with the hazardous substance involved and the spill volume and conditions. This individual will then determine whether the spill is:

• Incidental, and can be handled safely by site employees;
• More than incidental, and the ERP must be activated; or
• More than incidental, and external response organizations are needed.

If the spill is determined to be incidental, response personnel will rely on their training under the Personal Protective Equipment (PPE) and Hazard Communication standards to handle the spill. They may also be briefed as to spill conditions, response activities, decontamination, and waste handling.

If the spill is determined to be more than incidental, but response can be handled without outside help, the ERP will be activated, and each employee involved in the emergency response operation should be briefed on:

• The level of PPE and chemical protective clothing (CPC) required,
• Safety procedures,
• Isolating the spill and creating work zones,
• Tasks involved,
• Leak or spill control,
• Any medical care required, and
• Decontamination procedures.

Once the emergency is under control, post-emergency response procedures can be implemented. These will address cleaning up the area, decontaminating personnel and equipment, and properly disposing of the waste.

Post-spill-response evaluation

The spill response effort doesn’t end after control and cleanup activities are completed. Some common expectations and procedures for a post-spill-response evaluation — the last element of a spill containment program — include:

• Ensuring the incident is documented;
• Examining the root cause(s) of the incident;
• Examining response efforts;
• Implementing corrective actions;
• Replenishing supplies and equipment; and
• Ensuring medical, exposure, and monitoring records are completed and maintained.