What should the Plan Consist of

The standard requires that the containers used during containment and cleanup meet the OSHA and EPA standards. It does not, however, provide strict directions about what the secondary containment should look like, only that it should satisfy the volume requirement.

At a minimum, the plan should cover:

  • The nature and size of the potential spill
  • Hazards posed by the spill to the employees, the public, and the environment
  • Resources needed to prevent, contain, and control the spill
  • Responsibilities in the event of the spill
  • Training required for the first responders (employees responding to an emergency release should be certified in accordance to HAZWOPER standard 29 CFR 1910.120)
  • How to properly dispose of the waste

 The purpose of the program will be the protection of employees at the site and will be an extension of the employer’s overall safety and health program work. The program will need to be developed before work begins on the site and implemented as work proceeds. The program is to facilitate coordination and communication of safety and health issues among personnel responsible for the various activities which will take place at the site. It will provide the overall means for planning and implementing the needed safety and health training and job orientation of employees who will be working at the site. The program will provide the means for identifying and controlling worksite hazards and the means for monitoring program effectiveness. The program will need to cover the responsibilities and authority of the site coordinator for the safety and health of employees at the site, and the relationships with contractors or support services as to what each employer’s safety and health responsibilities are for their employees on the site. Each contractor on the site needs to have its own safety and health program so structured that it will smoothly interface with the program of the site coordinator or principal contractor.