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If you expected a potentially hazardous, or dangerous event was going to happen, wouldn’t you try to be prepared in advance to deal with it? You may tell your customers they need a plan of action in place, before cold weather comes, and snow and ice create a hazard at their property. The same is true for you and your business concerning a different type of hazard – oil or gas spills and leaks. It may not be as predictable as cold weather, snow, and icy conditions, but it’s pretty much a sure thing; eventually you will have a hydraulic hose blow out, a portable fuel can turn over, or an accident performing routine maintenance on equipment, resulting in a discharge of fuel or oil that requires action, and cleanup.

Whether it happens on your property, or on a customer’s property, oil and gas spills are a problem in many ways, ranging from an unsightly spot on your shop floor, or a customer’s parking lot, to the risk of contaminating the environment, or a serious fire hazard. Big or small, if you have a plan in place your crew will be prepared to respond quickly, and appropriately. And if the spill is on a customer’s property, how you respond can make the difference in a disgruntled customer, and one who is impressed with your preparedness and professionalism.

I’m sure you’ve heard the adage “hope for the best, but plan for the worst.” It’s sound advice, especially the plan for the worst part. We’re all pretty good at hoping for the best, and you may have an idea of what you’d do if you had an oil or gas spill, but if you haven’t written it down and trained your crew, it’s not a plan.

An Emergency Action Plan (EAP) lays out specific procedures for dealing with various types of emergencies, and you should have one written specifically for gas and oil spills. Creating an EAP isn’t as tough as you think, and it’s worth the effort for two important reasons.

  • Having an EAP in place will allow your crew to act quickly, and appropriately, decreasing the risk of contamination, and possible injury to workers, the public, your customer’s property, and the environment.
  • It’s the law! That’s right. OSHA requires employers to develop, and implement a written safety and health program, including emergency response procedures.

The best EAP’s are short, to the point, and easy for your crew to understand and follow. Here’s an example of an effective EAP for responding to oil and gas spills in five steps. Following these five steps will give you greater control of the problem, and limit any negative impact of the spill. Although a little hydraulic oil leaking on your shop floor may not seem like an “emergency,” having an EAP like this in place will assure that all spills are evaluated and handled correctly.

Evaluate/Rescue

When a spill happens, the first thing you should do is make a quick evaluation of the spill area and provide immediate assistance to anyone involved. You can quickly determine whether this is a minor spill, or a major spill based on things like; where the spill happened; is it highly flammable gas, or a less volatile oil product; approximately how much has been released; is there a fire or risk of a fire; has anyone been contaminated or injured. Most oil and gas spills are minor, based simply on the quantity of material released, but you can use these guidelines to categorize the spill. The rest of your actions will be based on this determination.

A minor spill is characterized by the following criteria:

  • The spill is inside, or on an impervious surface, and will not spread outside.
  • Did not result in a fire or explosion, and does not present the risk of fire. This is always a major concern with petroleum products, and should be carefully considered.
  • No one was injured or requires medical attention.

A major spill is characterized by the following criteria:

  • Results in a fire or explosion, or presents the risk of fire or explosion.
  • Personnel injured or requires medical attention.
  • Not easily contained on impervious surface and could impact the environment.

In a major emergency, like a fire too large to easily control, or if someone is seriously injured, you should immediately call 911 for fire or medical assistance.

Confine

Once you’ve made your evaluation of the situation, if oil or gas is still leaking, and you can do so safely (make sure to wear proper Personal Protective Equipment, and not contaminate yourself) try to stop the discharge and confine the leak. A piece of wood or a rag might be used to plug a hole in a fuel tank and slow a leak. Shutting down a piece of equipment will stop the hydraulic pump, and limit the release of hydraulic oil, or you may be able to lift a hose high enough to stop the flow from gravity.

Depending on where the spill occurred you may need to cover floor drains or protect storm sewer inlets to confine the spill. Create a dam with sand, soil or another sorbent to restrict movement, and prevent the material from entering drains or other outlets. Spill kits containing absorbent pads, pillows or loose absorbent material like kitty litter or floor-dri, PPE, gloves, goggles, boots, heavy plastic bags for cleanup, and signage to warn others to stay clear are very handy and should be readily available to all or your crews. Remember, your primary goal is reducing the risk of harm to any individuals so make sure you are wearing proper PPE, and don’t contaminate yourself while trying to contain the spill.

Report

Next, report the spill to a responsible person. Make sure your crew knows it’s important to report all oil or gas spills either to you, their supervisor or to a person you’ve designated as leader of a response team. If the spill is not on your property, you’ll need to inform the property owner. Be prepared to provide information on the material spilled, estimated quantity and location of the spill, and the steps your crew took for remediation.

In some cases, other agencies should be contacted. For larger spills, call the local fire department. They are trained to respond to accidents where gas and oil has spilled, and can provide help in confining, cleaning up, and of course fire control.

Reporting requirements for state and local agencies differ, but generally water contamination is the biggest concern. The EPA has established requirements to report spills to navigable waters, and many states require reporting, regardless of volume, if the petroleum “causes a sheen” on nearby surface water or if the petroleum is discharged 100 feet or less from any surface water body. The bottom line is if your spill is in a body of water or over 25 gallons, you need to contact federal, state and possibly local pollution control agencies.

Secure

For major spills, the area should be secured until an emergency response team arrives to make sure no one enters the spill area.

Cleanup and disposal

Cleanup should be performed quickly, using personal protective equipment and appropriate cleanup materials.

Small gas spills on an impervious surface are very volatile and will evaporate quickly. Maybe I should have mentioned this earlier, but I think it goes without saying, smoking near a gas or oil spill must be strictly prohibited.

Most oil spills are small and cleanup is just a matter of covering the spill with a sorbent like Oil-dri, Floor dry, kitty litter, sand, dry soil or an absorbent pad, and sweeping up that material for proper disposal. After you’ve picked up the first application, it’s a good idea to reapply the absorbent to collect any residual spill left behind. Place the contaminated sorbent in a bucket, heavy plastic bag or plastic trash can until it can be disposed of properly. Whatever container you use, make sure it is clearly marked as petroleum contaminated waste. Small amounts of contaminated absorbent can be stored for later disposal

The contaminated material you collect can be disposed of by land treatment, thermal treatment or incineration. Petroleum products are biodegradable. Sand, soil, kitty-litter or other “natural” absorbents like corncobs or wood chips can be spread over a vegetated land area, and will be “eaten” by bacteria and other microbes in the soil. For thermal treatment and incineration facilities, check with your state pollution control agency for a list of permitted sites. Incineration is the only approved method of disposal for socks and pads made from synthetic sorbents.

As mentioned above, call the local fire department for help cleaning up bigger spills. Spills that cannot be contained on an impervious service and contaminate lawns or landscaping may require the testing and removal of soil to a depth below the contamination.

That’s all there is to it

These steps can easily be revised to write your own EAP. Include specific information about your location, names and contact information for responsible parties within your company, phone numbers for fire departments near your customers, and for state and local pollution control agencies. Developing a written program is an important step that demonstrates your commitment to protecting your customer’s property, the environment and your employee’s safety.

Once you’ve developed your EAP, share it with your crew and hold mock accident training sessions. Hopefully you’ll never have a gas or oil spill, but that’s just hoping for the best. Developing an EAP, and training your crew, will mean you’ve also planned for the worst.

Mickey McCord is a workplace safety consultant and frequent snow magazine contributor.