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Can I self-Certify My Own SPCC Plan?
If your facility has the capacity to store more than 1,320 gallons of oil in aboveground storage tanks/containers, you are required to prepare and maintain an SPCC Plan per the requirements of EPA’s Oil Pollution Prevention Regulations (40 CFR 112). Historically, all SPCC Plans had to be reviewed and certified by a registered professional engineer, but with the adoption of the November 5, 2009 SPCC amendments, which became effective on January 14, 2010, facilities are now allowed to self-certify their own SPCC Plans if they have:
- An oil storage capacity of less than 10,000 gallons; and
- Not had a reportable release of oil to water within the preceding three years.
Please contact Brandon McDowell at 303-289-7520 ext 411 if you would like to discuss the applicability of the SPCC Rules to your facility or learn more about these self-certification options. You may also review our SPCC Webpage to learn more about the services we provide and for links to helpful SPCC information.
There are PCB’s in what? It is generally understood that PCBs (Polychlorinated Biphenyls) may be present in electrical transformers and capacitors, but did you know that PCB’s may also be found in other electrical equipment as well as non-electrical materials such as: |
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You must pay particular attention to materials that were manufactured between 1927 and 1982 as this is period in which PCB’s were manufactured within the United States. If you are in doubt, test suspect equipment to ensure you are in compliance with the disposal and on-site management requirements of the Toxic Substance Control Act (TSCA). Typically, analysis is performed per EPA Method 8082 and costs approximately $100 per sample.
If you have questions regarding what materials/equipment may contain PCB’s or would like help sampling your equipment, please contact Chris Abeyta at 303-289-7520 ext. 407. You may also visit EPA’s PCB website for additional information. |
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Must I Comply with the Electrical Safety Requirements of NFPA 70E? In short, yes. When OSHA revised its standards for electrical installations in 2007 (72 FR 7135-7221), they based their regulations on the 2000 version of NFPA 70E . Although, this rulemaking did not make revisions to OSHA’s electrical safety work practice requirements, OSHA did state that “the latest editions of NFPA 70E provide improved protection to employees through better electrical safety-related work practices” and that they are “planning to update these requirements as the next phase of the project to update OSHA's electrical standards.” Additionally, OSHA has indicated through letters of interpretation that a national consensus standard, such as NFPA 70E, “can sometimes be relevant to a general duty clause citation in the sense that the consensus standard may be used as evidence of hazard recognition and the availability of feasible means of abatement.” The general duty clause, Section 5(a)(1) of the OSH Act, is violated if an employer has failed to furnish a workplace that is free from recognized hazards causing or likely to cause death or serious physical harm. |
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Even more importantly to the safety of your employees, OSHA’s regulations clearly state that electrical safety work practices must be used, but they do not provide significant detail on how to accomplish this. This is where NFPA 70E is essential as it details what work practices must be followed to keep your employees and contractors safe from the hazards associated with working on live electrical equipment. Please contact Mark Jensen at 303-289-7520 ext 405 to setup a free on-site assessment or discuss how these rules apply to your facility. You may also review OSHA’s electrical safety website for additional information. |
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Upcoming Training Classes 40-hour HAZWOPER Refresher March 22-26, 2010 - Denver, CO 8-hour HAZWOPER Refresher March 15 , 2010 - Denver, CO |
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