OSHA’s regulatory scope is primarily concerned with workplace safety while the EPA is focused on environmental releases. Whether it’s under Hazard Communication, Material Handling and Storage regulations, OSHA expects you to have a written hazardous material spill management control plan.
To effectively develop a hazardous material spill management control plan, you will need to inventory your onsite hazardous chemicals, review each chemicals Safety Data Sheet (SDS) and follow the manufacturer’s recommendations for spill cleanup. You may find the necessary information in the product’s Safety Data Sheet to be very detailed in proper handling and spill cleanup of their product and sometimes not. If you have any questions as what the correct method is necessary for handling, storage, and spill cleanup, contact the manufacturer.
Your hazardous material spill management control plan must have the following:
It is imperative you have all the items needed on hand for spill cleanup as directed by the product manufacturer.
PPE required to be used during cleanup.
Methods and materials to safely flush, contain, isolate or neutralize spilled material.
Confirm your employees are capable of safely conducting the cleanup.
It is important your plan states when it is necessary to call in outside emergency services, fire department or hazmat team. Know your limitations.
Documentation of employee training of your plan is critical to being compliant if there is no documentation, it didn’t happen.
An annual review of the plan by a competent person to identify gaps overlooked in the process.