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In any chemical spill situation (technically called a release or discharge), employees with proper training may be designated or expected to respond. The use of a spill kit during initial response may lessen the severity of releases and keep control over emergency situations. Using a kit may also limit damages to life, property, and the environment.
A spill kit is a set of readily available equipment and supplies designed for use in the event of a chemical release. The kit helps the responder to quickly confine, contain, control, and/or clean up the release. A kit’s supplies will vary depending on the release size and chemical type for which the kit is intended. Spill kits and spill stations may come in a duffel bag, pail, bin, drum, cart, cabinet, trailer, or other container.
When people think about secondary containment, things that come to mind include dikes, berms, retention ponds, drip pans, and other “passive” measures. However, using spill kits with sorbent materials like “kitty litter” is an example of “active” secondary containment. Active secondary containment includes measures that require deployment or other specific action before or after a release. These actions are also referred to as spill countermeasures.
Scope
OSHA, EPA, and DOT do not specifically require a spill kit, but:
- It’s important for employees who are expected to respond to chemical releases to have the equipment necessary (or required) to handle their duties; and
- An employer is required to ensure that leaks and spills are quickly cleaned up, to prevent employee chemical exposure and to maintain walking-working surfaces that are free of hazards.
Many secondary containment regulations call for passive, not active, methods. In fact, they may have specific size and design provisions. This means spill kits may not be a compliant means of secondary containment, but instead they may only supplement passive systems.
However, some secondary containment regulations may allow for active secondary containment, and where that is the case, it is up to the facility owner or operator to determine if a spill kit is the best way to meet those requirements.
Note that spill kits are not the answer for all leak and spill situations. That’s because spill kits often have limited absorption or containment capacity. Chemical storage can pose a spill risk during off-hour periods when personnel may not be onsite to act. Also, precipitation and cold temperatures may affect the performance of spill kit components.
In addition to reviewing the applicable regulations, a facility owner or operator may wish to seek out a professional engineer and related consensus standards for recommendations.
Regulatory citations
- 29 CFR 1910.22 — General Requirements for Walking-working Surfaces
- 29 CFR 1910.120 — Hazardous Waste Operations and Emergency Response (HAZWOPER)
- 29 CFR 1910.178 — Powered Industrial Trucks
- 29 CFR 1910.1200 — Hazard Communication
- 29 CFR 1910.1200 Appendix D — Safety Data Sheets (Mandatory)
- 40 CFR 112 — Oil Pollution Prevention
Key definitions
- Discharge: Generally includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of an oil or hazardous substance.
- Emergency response or responding to emergencies: A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of 29 CFR 1910.120. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.
- Incidental spill: A release of a hazardous substance where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel.
- Release: Generally means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or contaminant).
- Secondary containment: Temporary containment of a discharge if the primary container fails. Secondary containment gives a facility time to abate the source of the discharge and remove the accumulated chemical to prevent it from reaching waterbodies.
Summary of requirements
- Maintain walking-working surfaces so they are free of hazards, including leaks, spills, snow, and ice.
- In powered industrial truck battery changing and charging areas, provide “facilities” for flushing and neutralizing spilled electrolyte and for adequate ventilation for dispersal of fumes from gassing batteries.
- For powered industrial truck operation, avoid spilling when fueling the truck and ensure that any spillage of oil or fuel is carefully washed away or completely evaporated and the fuel tank cap replaced before restarting the engine.
- Stay current with the most accurate information on hazardous substances at your facility. A hazardous chemical safety data sheet (SDS), for example, will provide appropriate “accident release measures.”
- Train each employee in the measures they can take to protect themselves from hazardous chemicals, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used. This training may include the use of a spill kit, if applicable.
- Ensure employees who will use the spill kit or otherwise respond to a chemical release also have the proper training and instruction per the HAZWOPER; Personal Protective Equipment (PPE); and Spill Prevention, Control, and Countermeasure (SPCC) Standards, as applicable.
- Determine what equipment and supplies are required or needed, and the locations that need them for the most likely spill volume expected. Typical items that might be found in spill kits, carts, and control stations include:
- Patch and plug kits to stop leaks;
- Loose sorbent materials like sawdust, vermiculite, or kitty litter;
- Materials like clay, vermiculite, or diatomaceous earth, packaged in pillows and socks designed to absorb liquids;
- Absorbent towels, pads, and/or mats;
- Drain covers or spill mats used to block or prevent the flow of spills;
- Booms for spills that float on water or sorbent-filled booms used for land-based spills;
- Temporary dikes, berms, curbing, or other barriers;
- Brooms, mops, shovels, scoops, scrapers, squeegees, flashlights, hammers, wrenches, or other non-sparking hand tools;
- Acid and base neutralizers;
- Environmental monitoring and sampling equipment;
- Salvage bags, buckets, and/or drums to contain or collect spill material and waste;
- Signs, tags, labels, barricade tape, and writing equipment;
- Two-way radio, cell phone, phone numbers, and/or other communication equipment;
- Medical and first-aid supplies;
- Fire-fighting equipment; and
- Coveralls, gloves, goggles, face shields, boots, boot covers, respirators, masks, or other PPE and chemical protective clothing.
- Consider the following factors (in addition to any regulatory requirements) when selecting the type and quantity of equipment:
- The types of spills that may arise. Consider the probable and worst-case scenario;
- The types of hazards that employees may be exposed to and the appropriate containment, mitigative, and protective measures;
- The capabilities and estimated response times of off-site responders;
- The number of site employees who could be victims during the release incident; and
- The probable number of personnel available for response.
- Maintain an adequate supply and refill when necessary.
- Determine which, if any, of the federal (and state) secondary containment regulations and permit requirements apply to the facility. Examples are listed in the Secondary containment ezExplanation. Consider the type of materials present and the nature of the onsite operations.
- If secondary containment regulations and permit requirements apply, be sure to meet them. Consider consulting a licensed professional engineer to ensure the secondary containment not only meets the requirements but follows good engineering practice and industry standards.