Basic preplanning for leaks and spills
Response to small spills as important as worst-case scenarios
By Karen Hamel
Leaks, drips and overspray are an inherent, often unremarked part of many production activities. Moreover, incidental spills from tanks, hoses, lines and containers are also frequently overlooked in many facilities.
Because they are so common, routine leaks and spills can sometimes be missed when facilities review safety hazards. But these small “inconveniences” are a leading cause of slip-and-fall incidents, the most common type of lost work-time injury in the United States, according to the U.S. Bureau of Labor Statistics.
Focusing good housekeeping efforts on leak- and spill-prone areas throughout the facility — and being prepared for spills before they happen — decreases the likelihood of slip-and-fall incidents and increases the ability of workers to take care of spill situations quickly and efficiently.
Identify leak-, spill-prone areas
A variety of Environmental Protection Agency (EPA) regulations focus on requirements for proper storage and handling of hazardous materials in tanks and containers. They require facilities to have plans in place to deal with worst-case scenario spills of hazardous materials and wastes.
While these response plans are certainly necessary, well-maintained containers and tanks fail only rarely. Data from the National Response Center (NRC) shows that most reportable spills in fixed facilities are less than 10 gallons, making response preparations for small spills equally as important as plans for worst-case scenarios. Determining where spills are most likely to happen is the first step in being prepared.
Obviously, spills are less likely in office areas and meeting rooms than in other areas of a facility, so stocking spill response kits and training office staff probably isn’t the best use of time or resources.
Some facilities have unique spill hazards, but many share common problem areas.
Wet, slippery floors in production areas are often caused by overspray from coating operations, coolant used during cutting and grinding processes or leaky machinery. Acid or caustic baths and wash tanks are other common sources of leaks and drips.
Areas where fluids are transferred, such as bulk-fluid offloading areas, fluid-dispensing stations, satellite accumulation areas and central waste-collection areas are all prone to leaks and drips as fluids are moved from one tank or container to another. Spills in fluid-transfer areas can range from a few drops of used oil that drips from a drain pan as the oil is collected in a drum, to several gallons that leak when a hose is disconnected from a bulk storage tank.
Forklift battery charging stations, laboratories, fleet maintenance shops and loading docks are additional nonproduction areas also prone to leaks and spills. Use a current floor plan of the facility to mark or highlight spill-prone and wet areas so that planners know where to best concentrate spill preparation and response efforts.
Stocking response supplies
It is up to the facility to determine what tools, materials, plans and resources will work the best for its spill scenarios. It is very possible that different spill response techniques and tools are needed at different points throughout a facility. Very rarely will one type and size of spill kit or piece of response equipment be appropriate for every spill-prone area.
Consider the potential volume of liquids that could be spilled in each area as well as the types of response materials that will be most beneficial. Response items can easily vary from something as small and simple as a paper wiper to something as large as a 30,000-gallon vacuum truck. No matter what the size, matching response items to the task and to the abilities of the people responding are important for both safety and efficiency.
To ensure incidental leaks and drips don’t become slip-and-fall hazards, it may be enough to provide indoor fluid dispensing and waste collection areas stocked with wipers and a waste receptacle to encourage workers to clean up incidental leaks and drips as they happen. Spill response kits can help speed response in waste collection, bulk fluid transfer and other areas where higher volumes of liquids are used and stored.
Absorbent matting or grating on floors and aisles in production areas with overspray improves floor safety wherever constant leaks and drips can’t be cleaned up as they happen. Berms can also be used to help contain routine leaks and spills around the bases of machinery in production areas so that they can be vacuumed for recovery and recycling.
When stocking response supplies in spill-prone areas, consider including personal protective equipment, disposal bags, cleaning solvents and other items that responders will need to accomplish their cleanup tasks. Having all items stored together in a convenient location encourages fast response, as time is not spent gathering equipment, or retrieving it from a distant storage locker.
Training workers to respond
Employees responding to large or emergency releases must be trained to an appropriate level of OSHA’s Hazardous Waste Operation and Emergency Response (HAZWOPER) standard (29 CFR 1910.120). Those responding to incidental spills must also be trained, but may not require HAZWOPER training. Some facilities incorporate incidental spill response elements into hazard communication or other safety trainings.
All employees should be able to identify a spill and know what actions are to be taken — even if the only thing they need do is pull an alarm and evacuate. Trained employees who work with fluids every day should be able to clean up incidental spills quickly and safely. They should also know how to tell whether a spill is incidental or if it is an emergency, what personal protective equipment is needed while responding, and what to do with spent response materials.
As a follow-up to training, hosting regular drills will allow employees to demonstrate their ability to use response tools and supplies. Drills are also a great way to evaluate plans to ensure that they work and that everyone is comfortable with the steps that need to be taken.
Planning for spills and being prepared to handle them before they happen won’t eliminate spills — but it will help ensure that when they do happen, everyone knows what to do to minimize the hazard and respond safely.
Karen D. Hamel is a technical specialist for New Pig Corp. She has more than 19 years of experience helping environmental, health and safety professionals find solutions to meet EPA, OSHA and DOT regulations. She is a graduate of the University of Pittsburgh, has completed several NIMS courses, is a HAZWOPER technician and serves on the Blair County, PA LEPC. She can be reached at 1-800-HOT-HOGS (468-4647) or by email firstname.lastname@example.org.