As web-based technologies become more accessible and mobile, different options for hosting and managing response plans have evolved. Transitioning to a web-based cloud system to maintain your Spill Prevention, Control, and Countermeasure (SPCC) plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.
Environmental, health, and safety (EHS) managers responsible for maintaining regulatory compliance for multiple sites may benefit from web-based cloud computing for emergency management. While cloud technology isn’t a new concept, a recent survey conducted by IT industry association CompTIA, found that more than 80% of companies use or have transitioned to some form of cloud technology. The survey revealed that costs, increased flexibility, and newly available resources are the main motivation for moving to a cloud. The costs associated with effective emergency management, planning efforts, and overall spill prevention are often much less than the costs associated with spill clean up, fines, and other civil liabilities.
The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:
A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.
EHS managers responsible for maintaining SPCC compliance can maximize department efforts and communication. With budgets restraints and increasing workloads, reducing plan maintenance costs, improving communication methods, and minimizing preparedness disparities is critical. Word documents, PDF files, and printed binders are burdensome, administratively time-consuming, and possibly inaccurate or non-compliant.
Here are some questions to determine if web-based cloud technology SPCC plan system is right for your company?
- Do you have multiple facilities that are governed by SPCC and/or other regulatory requirements?
- Is there repetitive company information in multiple response plans?
- When was your last SPCC or facility response plan (FRP) audit and would you be ready if an auditor appeared tomorrow?
- Does your company already utilize cloud-based technology?
- How effectively do you handle contact information updates and verification? How often does this occur?
- How often do you print updated plan copies for distribution, and what costs are involved?
- How audit-friendly are your plans?
- How many individuals have access to your plans and are authorized to make updates?
- Are your plans updated quarterly or annually?
- How are new regulatory requirements incorporated into plans?
- How much time is dedicated to maintaining and updating your plans?
- Do you have a record of changes and revisions?
But with a cloud system, redundancy and back up efforts are essential. In the event Internet connectivity is terminated or inaccessible, emergency managers must have alternative means to access plans. Redundant data centers, scheduled downloads, and security measures must be a part of any emergency management program based on an intranet or cloud.
Response plans housed in cloud technology also has numerous benefits. When employees are equipped with Wi-Fi enabled devices, authorized users can access response plans information from any location. This can aid in response measures if the incident is isolated to a particular location. SPCC plans can also be readily shared with other company locations and external responders who can relay important detailed facility information to those onsite. Additionally, dedicated administrative time associated with plan maintenance, updating, access, and regulatory submission can be minimized.
The following EPA list highlights some important elements of an SPCC Plan:
- Facility diagram and description of the facility
- Oil discharge predictions
- Appropriate secondary containment or diversionary structures
- Facility drainage
- Site security
- Facility inspections
- Requirements for bulk storage containers including inspections, overfill, and integrity testing requirements
- Transfer procedures and equipment (including piping)
- Requirements for qualified oil-filled operational equipment
- Loading/unloading rack requirements and procedures for tank cars and tank trucks
- Brittle fracture evaluations for aboveground field constructed containers
- Personnel training and oil discharge prevention briefings
- Recordkeeping requirements
- Five-year Plan review
- Management approval
- Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.