From time-to-time, Caltha receives inquiries from facilities that believe their Spill Prevention, Control & Countermeasure (SPCC) Plan may have “expired“.
The SPCC Plan, prepared in accordance with 40 CFR 112, is a “dynamic” document, and does not expire. However, at any point in time, the SPCC Plan needs to accurately reflect the current physical layout of the facility, the existing spill containment and control measures, and the current emergency response procedures.
Because facilities change overtime, the SPCC Plan needs to be reviewed and updated accordingly. At a minimum, the plan needs a formal review and revision (if necessary) every five years. However, certain elements of the Plan may change much more frequently – especially emergency contact information. The SPCC Plan should be revised before making changes to the facility that are relevant to compliance with the SPCC Rule.
Caltha LLP offers expert technical and regulatory support to develop facility Spill Prevention, Control & Countermeasure (SPCC) plans, including several low cost options for SPCC Plans using the new SPCC Template Plan format. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112.