We’re seeing an increasing number of UST sites today that are outfitted with emergency spill response kits. But because a spill response kit is not specifically required in Federal and many state UST rules, it’s not something state inspectors are necessarily looking for. Meanwhile, many to most of the larger UST companies have had spill skits on-site, stocked and ready to deploy for many years.
If you don’t yet have a spill kit at your UST site, consider the following useful information provided by our good friends at the Vermont DEC.
The information provided on this page is a best management practice (BMP) that does not necessarily reflect requirements of the Vermont Hazardous Waste Management Regulations (VHWMR). While the VHWMR specify that small and large quantity generators be equipped with spill control and decontamination equipment (i.e., spill clean-up materials), the regulations do not specify what materials or equipment must be maintained. If you are unsure or cannot determine what your facility needs to include in a spill kit, you should seek the assistance of a consultant or other environmental professional.
Also note that the following recommendations may not meet the spill kit requirements of EPA’s Spill Prevention Countermeasure and Control Planning regulations.
A spill kit is a collection of items to be used in the immediate response and clean-up of spills, leaks or other discharges of hazardous wastes or other hazardous materials (chemical spills). Spill kits should be maintained in close proximity to areas where chemicals are managed or stored to enable prompt response and clean-up of spills.
Employees should be familiar with the location and contents of all spill kits and the procedure(s) to be followed in the event of a chemical spill. A procedure, or set of procedures (i.e., response may vary with type of chemical spilled), should be developed for proper spill kit use and to assist employees in the event of an emergency. All employees who work in areas where chemicals are managed should be trained in spill kit procedures and the appropriate response to chemical spills and other emergencies. Emergency contact information should also either be posted or included in spill kit procedures. It is important to note that, for some chemical spills, the best response is facility evacuation. Employee training should clearly address when not to attempt handling spills and to call in emergency response professionals.
The contents of a spill kit will vary depending on the type and quantity of each chemical used at a facility (or area within a facility). When constructing spill kits, the type and amount of equipment compiled for each kit should be sufficient to address any spill that employees can safely respond to. As mentioned above, procedures and training should inform employees about how to safely use spill kits, what size spill can be safely managed, and when to stop and contact emergency response professionals for assistance.
A typical spill kit will contain three types of equipment:
- Personal protective equipment (PPE)
- Equipment and materials to clean-up small spills
- Equipment to contain larger spills
A spill kit should include heavy-duty gloves made of nitrile or neoprene, chemical resistant safety glasses (goggles for areas where chemicals that may irritate eyes are used such as acids), and a disposable lab coat or apron. For areas where larger spills could potentially occur, a disposable protective suit and boot covers should be included. Other protective equipment based on specific facility conditions may also be necessary (e.g., hard hat, steel toe boots, or dielectric equipment).
Again, the contents of a spill kit should be tailored to the types and quantities of chemicals that can potentially spill. While granular absorbents and spill pads and booms can be used to clean-up or contain most spills, not all spills are created equal. For example, some spilled chemicals must be neutralized prior to being absorbed. Also, it’s critically important to be aware of situations where incompatible chemicals and/or clean-up materials are co-located and could potentially come in contact with each other.