If your facility already has a Spill Prevention, Control and Countermeasure (SPCC) Plan in place, you’ve taken an important step toward preventing oil spills and staying compliant with EPA regulations. But SPCC plans aren’t one-and-done. Just like your operations, they need periodic review, and sometimes, a complete refresh.
Whether you self-certified your plan or had it prepared by a professional engineer (PE), it’s your responsibility to make sure what’s written still reflects your actual site conditions and operations. Many facilities discover, often during an inspection or after a spill, that their SPCC Plan no longer meets the mark, exposing the facility to compliance violations, operational inefficiencies, and greater risk in the event of a spill.
EPA Review Requirements: The Bare Minimum
The SPCC Rule (40 CFR Part 112) requires that every SPCC Plan be reviewed at least once every five years. This five-year mark is the bare minimum, and it’s often not enough to keep up with real-world changes.
The EPA also requires that if you make any change that could affect how your facility prevents or responds to an oil spill, you must amend the SPCC Plan within six months. Then, those changes must be fully implemented within another six months.
This includes updates like:
- Installing or removing oil storage containers and oil-filled equipment
- Altering your secondary containment structures
- Changing how or where oil is transferred
- Modifying stormwater drainage or site layout
- Implementing or substantially revising procedures
Even without storage or equipment changes, many facilities fall out of compliance simply because the plan hasn’t been reviewed or kept up to date. The risk? You could be out of step with EPA expectations and not ready to respond effectively if a spill occurs.
Key Warning Signs Your SPCC Plan Is Outdated
You don’t need to wait for an inspection or worse, a spill, to find out your plan is outdated. Here are some clear signs that it’s time for a review.
Time Since Last Review
If it’s been over five years since your last documented review, your plan is automatically out of compliance. That’s an easy one to fix, but it’s a common oversight.
Site Changes
Changes to your oil storage and equipment, site layout, or infrastructure, even small ones, can shift how oil moves (or could move) across your property. If the plan doesn’t reflect current storage locations, quantities, containment areas, or transfer zones, that’s a problem.
Staff Turnover
Personnel turnover can also affect your plan. If your designated SPCC Coordinator or emergency contacts have changed, your training program and contact lists may be outdated.
Warning Signs
Finally, if you’ve had a spill, near miss, or failed inspection, take that as your cue to reevaluate your procedures. These incidents usually signal that something isn’t working as intended, and your plan should be updated to reflect the lessons learned.
Keep Your Plan Aligned with Your Facility
SPCC Plans are site-specific for a reason. They need to reflect the real conditions at your facility today, not what things looked like years ago. That means ensuring your facility diagram is accurate, all oil containers and equipment (including drums and totes) are accounted for, secondary containment is properly described, inspections records are complete, and emergency contacts are up to date. Just as importantly, annual SPCC training should be conducted and documented consistently. Regular reviews not only keep your plan compliant, but they also protect your facility from costly enforcement actions.
If you’re unsure whether your plan reflects your current site conditions, Tetra Tech can help you assess your SPCC compliance and update your documentation before an inspection puts you at risk.
Make SPCC Review Part of Your Routine
Rather than treating SPCC updates as a regulatory chore, the most effective facilities build SPCC Plan reviews into their broader environmental, health, and safety (EHS) routines.
An annual internal review, even if formal changes aren’t needed, can help identify small issues before they turn into larger problems. Walk the site, double-check your diagrams, and make sure your records are complete. If you’re planning an operational change, involve your PE early so the plan can be updated and certified on time.
Routine maintenance of your SPCC Plan also reinforces a culture of awareness around spill prevention. That goes a long way in keeping your team ready and your facility protected.
Final Thoughts: Don’t Wait for a Violation
An SPCC Plan is only useful if it’s accurate and ready to guide your facility during an actual spill event. And from a compliance perspective, outdated plans are one of the most common violations cited during EPA inspections.
If it’s been more than five years since your last review, or if your facility has changed in any way, it’s time to take another look. A well-maintained SPCC Plan protects more than the environment. It protects your people, your operations, and your reputation.
Whether you need to review your SPCC Plan, update it to reflect recent site changes, or ensure it’s ready for EPA inspection, Tetra Tech’s SPCC experts can help. Contact us at [email protected] with your SPCC questions or to schedule a compliance review. We’re here to support your spill prevention efforts.
