A Guide for Chemical Spill Response

By: Darcy Cook, CHSO, SHS, PTA

If you google spill response for OSHA you are going to be challenged to find information in the regulation on spill response other than in Emergency Action Planning. But for an everyday hazardous chemical spill, there are more steps you will need to take to get your answers.

OSHA does not require a spill kit in the workplace but there are many regulations that indirectly require you to have a plan, resources, and training to respond to spills in the workplace. Remember, OSHA does enforce under the General Duty Clause.

If you do not have a spill response plan, training, or equipment ready to go when a spill happens, it could result in injuries, OSHA or DEP fines, delays and disruption to production and operations, evacuations or even damage of raw materials.

Prevention will always cost you less than being responsive to an incident. Consider these best practices and questions;

1. Define your chemicals as stored, in use or hazardous waste.
2. Do you have accumulations stations? Satellite locations? Are signs posted and barricades used when necessary?
3. Make sure anywhere chemicals are stored they are protected from being hit by a forklift or other moving power industrial trucks.
4. What are you using for spill containment? like spill containment pallets, cabinets, or drum containment?
5. What is the largest volume that is likely to spill/leak? Do you have a spill kit with enough materials inside to respond?
6. What are you using in your spill kits? Is it appropriate? Speedy Dry is a great choice for many manufacturers with oil exposures.
7. Do you have a long handle dustpan and broom? Do you put the absorbent pads in trash or into a container labeled as waste? Are you allowed to put it into regular trash?
8. Did you choose employees best suited for responding to a spill? Did you practice a spill drill?
9. Have you identified the highest risk chemicals? Are they on a list and are employees aware of what chemicals they can clean up, when to evacuate and when to call a third party?
10. Do you have a third party already on contract?
11. Do you have safety data sheets accessible at all times?

Write A Spill Response Procedure

Every manufacturing should develop a written spill response procedure detailing the initial steps to take when a spill occurs and include such elements as staff responsibilities, communication methods, instructions on using spill response equipment, and spill cleanup and disposal. Writing a procedure from behind a desk is only part of the process. Then practice it. Yup, go kick a 5-gallon bucket of water over and see what you learn about your process, training, equipment, and resources. This is where we typically identify gaps and areas for improvement. We love spill drill day.

We all get better with practice.

Make sure you have a revision date for your procedure every year. We want to know that you reviewed it, and that the procedure still makes sense based on any changes you have made.

Documentation

After cleaning up a spill, you should have a form to fill out. Do you have one? This report should be used for continuous improvement. What changes did we make or will we make to decrease the risk or likelihood of this happening again.

Make sure you know the rules on when to call DEP when you have an outside chemical spill.

Prevention always costs less. Have a plan, do training and practice. If handled improperly, a spill can seriously disrupt your business operations.