EHS Inspections: Focus on SPCC Plans

June 5th, 2025 by Dakota Software Staff

Environment, Health, and Safety (EHS) inspections are essential to ensure compliance and create a strong culture of safety in the workplace. In this recurring series, we’re diving into the most common challenges facing EHS pros—and providing quick inspection tips to help address them.

Spill Prevention, Control, and Countermeasures (SPCC) Plans – Wherever there’s oil, there’s the potential for a spill—and spills can be potentially devastating to the surrounding environment. To mitigate the risk, the Environmental Protection Agency (EPA) requires covered facilities to develop (and periodically test/inspect) SPCC Plans under the Clean Water Act (CWA) and the Oil Pollution Act (OPA).

The What and Why of SPCC Management

What it is: General requirements for SPCC Plans are outlined under 40 CFR 112.7. The plan must include a description and diagram of the facility, marking the locations and contents of oil storage containers, connecting pipes, and transfer areas (including underground tanks and certain gathering lines that are otherwise exempt from SPCC requirements). SPCC regulations also address containment systems (primary and secondary), personnel training, and security. These rules are intended to contain discharges of oil and prevent them from reaching navigable waters and the surrounding environment.

While SPCC regulations primarily address oil spills, EHS leaders may also choose to apply the principles of SPCC plans to contain spillage of other hazardous substances or wastes.

Why it matters: SPCC Plans ensure that organizations that produce, gather, store, use, or consume oil and oil products are prepared to prevent spills whenever possible and react and control any spills should they occur. Failing to contain oil discharges results in numerous consequences, including:

• Adverse effects to waterways, wildlife, and agriculture;

• Increased risk to employee health and safety through slips and falls;

• Financial impact resulting from citations, fines, and penalties; and

• Reputational consequences from polluting the surrounding community.

Steps for an Effective SPCC Inspection

Inspections and tests of SPCC plans are required under 40 CFR 112.7(e), and signed written records of these inspections must be kept for a period of three years. The following items can be organized into an inspection checklist for SPCC and should allow space for commentary where test results, descriptions of corrective action, or any other notes may be necessary.

Administrative requirements

• Does your facility diagram mark all locations of oil storage containers as well as any areas where mobile or portable containers are kept?

• Does your SPCC plan outline the type of oil stored in each container and its storage capacity?

• Does the plan include countermeasures for oil discharge discovery, response, cleanup, and disposal?

• Is an up-to-date contact list of facility response coordinator(s), National Response Center, cleanup contractors, and all appropriate regulatory agencies (including phone numbers) readily available in the event of a discharge?

• Are written, signed records of SPCC inspections and tests kept on hand for three years?

Containment systems

• Does your facility have primary and secondary (active or passive) containment systems in place as appropriate?

• At a minimum, does the containment system employ one of the following elements (or its equivalent) as outlined in 40 CFR 112.7(c):

• Dikes, berms, or retaining walls sufficiently impervious to contain oil;

• Curbing or drip pans;

• Sumps and collection systems;

• Culverting, gutters, or other drainage systems;

• Weirs, booms, or other barriers;

• Spill diversion ponds;

• Retention ponds; or

• Sorbent materials?

Training and procedures

• Are all oil-handling employees trained to prevent discharges during the maintenance and operation of equipment?

• Are employees (as necessary to their job duties) trained in spill control and countermeasure procedures in the event of a discharge?

• Are discharge prevention briefings scheduled and conducted at least once a year to ensure oil-handling employees have an adequate understanding of the facility SPCC plan?

• Are all oil handling, processing, and storage areas properly secured and equipped with adequate lighting to ensure only authorized access, prevent vandalism, and ensure prompt detection of oil spills?

This checklist provides a head start for SPCC inspections, but every operation is unique, and you should develop your plans to meet your specific compliance obligations. EHS software can help ensure that your inspections are tailor-made to the needs of your business.

EHS Inspection Management Made Easier

EHS inspections rely on proper completion and management of checklists—and it can be a complex undertaking. Depending on the size and nature of their organization, EHS leaders need to ensure timeliness, consistency, and accuracy of inspections across departments and facilities.

That’s why EHS software is essential for inspection management. An integrated software solution has the ability to standardize forms and processes, maintain compliance calendars, push reminders, and keep easily searchable records of results. Perhaps most importantly, software can provide insights into the resulting inspection data via comprehensive analytics dashboards. Instead of simply filing away checklists and forgetting about them, software can illuminate where your EHS programs are succeeding and point out areas where additional training or other corrective actions may be necessary.

Software Solutions with an Eye for Safety

Inspections help EHS leaders maintain the vigilance necessary for safety and environmental compliance—and software solutions provide the power to manage it all effectively. Dakota Inspections allows you to create and share checklists tailor-made to your organization’s needs, plus track progress to guide corrective action.

Start your free trial today.