Various federal Occupational Health and Safety (OSHA) and Environmental Protection Agency (EPA) regulations require facilities to create plans and be prepared to handle spills. Terms such as "worst case scenario" are often used to describe the largest volume spill that a facility must be prepared to handle.
Most facilities have taken the time to create response plans and stockpile or earmark items for response to major catastrophes. Unfortunately, small or routine spills are sometimes overlooked or viewed as a maintenance not spill response function. Taking a closer look at these more common spills can help facilities be better prepared to safely handle these situations.
Consider locations where spills have happened in the past. Internal spill response reports or maintenance logs can sometimes help uncover trends, as well as frequency of spills. It is not uncommon to discover that spill locations almost directly correspond to the areas where liquids are routinely stored, transferred or handled.
Forklift collisions or grazes in high traffic areas, and areas requiring tight maneuvering are also common locations for spills. Don't overlook non-processing areas such as bathrooms and shower rooms. Slow drains that cause water to back up into aisles or processing areas can be a bigger nuisance and hazard than a 5-gallon spill in the back of the warehouse.
If the facility is new, is fortunate enough to have had few spills, or if documentation is not conclusive, a quick walk through the facility or at least a look at a detailed drawing or blueprint can help identify the locations of fluid storage, transfer and handling areas. While documenting these areas, determine what liquids are stored, and at what quantities.
Knowing where liquids are stored and how much is in each area helps coordinators properly plan for spills. Determine what strategy will work best at the facility. For small facilities where most liquids are stored, transferred or handled in one area, a single spill kit and response tools may be plenty.
For larger facilities where liquids are stored, transferred or handled in many areas, it may be more prudent to have several small stations than to have workers running to the other end of the building for supplies. The easier it is for workers to access supplies, the more likely it will be for incidental spills to be properly and quickly handled.
Before purchasing fancy spill response items, consider how workers currently handle small spills if workers handle them at all. No law requires you to purchase a specific product to handle spills. If workers currently handle small spills themselves in a particular way, making sure that the items they need are easily accessible in the locations where spills are likely to occur may be the only preparation necessary.
Spill response supplies may not be the same for each area. Where a battery filling station may require special absorbents and neutralizers, these items would be overkill in a shower room where a good squeegee is all that is needed to get excess water under control.
It's a good idea to note the locations of spill stations in contingency and other response plans, and to inspect each one routinely or after any reported incident to make sure that they remain properly stocked. Checklists can help facilitate these inspections.
Creating the best plans in the world and stocking mountains of supplies won't help keep spills in check unless workers know why spill response is important and are taught how and when to handle spills.
Teach workers to be aware of hazards. Containers hanging over an edge, puddles in a walkway or strange smells are some examples of hazards that anyone can be taught to recognize.
Determine the extent to which workers will be trained to mitigate spills. Under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120), various levels of training are specified for spill responders. While in many cases it is probably not practical or beneficial to train every worker to the technician level, elements of this standard could be incorporated into trainings to help ensure safety and provide a framework for proper response.
Ensure that workers and supervisors know their limitations when responding to spills, and that they work within their abilities. Cleaning up an ounce or two of oil that overfilled at a dispensing station is much different than trying to clean up a spill from a punctured 55-gallon drum of acetone on a hot day.
The first scenario is something that is likely to be within the scope of most worker's training and abilities. The second scenario is one that requires more extensive training to help ensure the safety of everyone involved in the response efforts. It is also one that will likely require more than one person to mitigate. Help workers to know when they can handle a situation on their own, and when to call for help.
In addition to spill awareness, take the time to explain what equipment is available to assist them in clean up, where it is stored, how it is to be used, and whom they should notify if or when products are used and need to be replaced.
Reporting and Reviews
Encourage workers to report spills or conditions that could lead to spills, and review them in safety committee meetings. While taking the time to review every dribble from every pump would probably make for a long safety meeting, reviewing notifications of overhanging containers, crowded aisle ways and other similar situations could identify the need for additional storage space or other adjustments that would make areas less spill-prone.
If reports show trends, review response plans or workflow in an area to determine where changes could be made to remedy the situation. If changes are made to plans, ensure that everyone is updated on those changes so that they can be properly implemented. Response plans should be living, working documents that are continually improved to the benefit and safety of everyone.
Chances are good that with proper facility maintenance and training, "the big spill" may never happen. Planning and preparing for smaller spills can help improve safety and worker morale while helping to ensure greater overall compliance.
For more information on spill response plans and products, visit New Pig Corp. at www.newpig.com.