SPILL CONTAINMENT PROGRAM
THE PROBLEM: The Hazwoper Standard requires employers to implement a spill
containment program as part of the site-specific Health and Safety Plan (HASP). The purpose of
the spill containment program is to set out procedures to contain and isolate the entire volume of
a hazardous substance spill and minimizes worker exposure to hazardous substance spills.
HOW TOOL HELPS SOLVE THE PROBLEM: Although the spill containment program—
like the overall HASP—must be site-specific, the Model below can be used as a general template
that you can adapt. Like the Model, make sure that your own spill containment covers at least the
following elements:
tial spill actions and response;
Spill cleanup procedures;
; and
-incident review and evaluation.
ABC COMPANY
SPILL CONTAINMENT PROGRAM
1. PURPOSE
The objective of this section of the HASP is to meet the requirements of 29CFR 1910.120
(b)(4)(ii)(j). The spill containment program must address all hazardous substance spill scenarios
that are likely to occur at the site, and must also provide procedures to contain and isolate the
entire volume of any hazardous substance spilled in the course of a transfer, accident, or onsite
release.
2. PREPLANNING
To develop a successful spill containment program, an assessment must be conducted of the site
conditions, current operations and planned activities. The assessment must carefully examine all
hazardous materials on site for where and how the materials are:
, location, type of container);
, processed, used, transferred); and
Each area or activity must be analyzed for potential accidental releases or spills. Examples of
situations that have potential for spill or release are:
Bulging or corroded containers;
seals, misaligned connections);
Metal fatigue of storage tanks;
Leaking or inoperable valves; and
Many potential spills can be avoided through application of proper engineering controls to
hazards identified in the assessment. In areas where storage, handling, and transportation
activities occur, preplanning to contain the largest volume of material that could be released in
the area will minimize worker exposure. The containment measure must be appropriate to the
hazardous material(s) identified and must be installed in the area or located nearby. Examples of
measures most frequently used:
Salvage containers (e.g., overpack drums);
Bermed, lined pads;
ike;
Procedures must be developed to properly maintained and replace, as necessary, all spill
containment equipment and fixtures.
3. REPORTING & INITIAL SAFETY
Upon discovery of a hazardous substance spill, personnel must be instructed to:
Health Officer (SSO), and/or the Project Manager;
4. INITIAL SPILL ACTION
Factors that limit the employee's response at the site of a spill include:
Level of training;
Personal safety;
onal protective equipment (PPE); and
Knowledge of the substance.
Employees must limit their actions to those that will not endanger themselves or others which
might include:
Shutting off equipment or pumps;
Closing valves;
ns within the path of the spill; and
Unauthorized persons must be excluded from the area.
5. SPILL RESPONSE EVALUATION
The identity and hazards of the spilled material must be determined before decisions about spill
containment and control are made. The SSO or Project Manager must evaluate the hazards
associated with the spill and decide whether project employees or external response
organizations must conduct the cleanup. If the Project Manager determines that project response
personnel cannot safely perform the spill cleanup, the Project Manager must notify and request
the assistance of, the Emergency Response Coordinator, and the ERP must be activated.
6. ORGANIZING A SPILL RESPONSE
If the Project Manager determines that cleanup can be performed safely with project response
personnel, the SSO may act as the spill team leader and designate required procedures. Safety
practices for small spill operations closely parallel procedures implemented during routine
hazardous materials handling operations. Before work begins, the SSO must conduct a hazard
identification and assessment with response personnel. The following must be discussed and
established:
ls of PPE and safety procedures;
Safety and work zones;
teps of the response activities;
es or methods for cleanup;
Means of containment;
Leak or spill control;
Decontamination procedures; and
7. SPILL CLEANUP PROCEDURES
After care of injured personnel, containment of the released hazardous material must be the next
consideration to limit its effect on the safety of personnel, the public, and the environment. The
SSO must determine the methods of control which depend upon the nature and extent of the
spill. Actions documented in the Emergency Response/Contingency Plan of this HASP must also
be consulted. Decontamination must be accomplished in accordance with the Decontamination
section of this HASP and disposal of contaminated materials must meet all regulatory
requirements.
8. POST-INCIENT FOLLOW-UP
The Project Manager or SSO must implement necessary steps to ensure that the incident is
properly documented and that spill response equipment is replenished. The Project Manager
must direct the necessary corrective actions to prevent recurrence and evaluate the response.