Imagine you’re going about your daily work routine and you receive a call that a gearbox has just discharged oil everywhere. You go into reactive mode. You haven’t arrived on the scene yet to assess the extent of the situation, but you have a general idea of what needs to be done – stop the equipment to prevent further damage and put down material to absorb the oil that has leaked out already.
Next, you think about how to fix the equipment. Exactly how much oil has leaked out? How much oil was in the equipment? Did the oil reach a drain or water source? Do you have the proper tools and equipment to handle a situation like this? Do you need to notify your state’s department of natural resources? Could the situation have been prevented?
Unfortunately, this is the reality many people face everyday when they report to work. At any time, an accident or machine failure could occur, discharging oil. The good news is you can prepare yourself and others for these situations before they arise. In some circumstances, government regulations may come into play. Therefore, it is important to know what these regulations are and if they apply to your plant.
OSHA and EPA Regulations
According to the U.S. Environmental Protection Agency (EPA), any container that can hold 55 gallons or more of lubricant is considered bulk lubricant storage. This means it is not necessary to count the storage volume for top-up containers, 5-gallon pails and even small equipment. However, you will need to concern yourself with containers that have a capacity of 55 gallons or more, including gearboxes, reservoirs, hydraulic units, storage containers, etc. These capacities should be included in your total oil storage amounts when determining whether federal regulations apply.
The Occupational Safety and Health Administration (OSHA) breaks down this accumulative amount into 1,320 gallons of above-ground storage and 42,000 gallons of underground storage. Facilities with accumulative amounts less than these volumes will not be required to have a Spill Prevention, Control and Countermeasures (SPCC) plan. Still, it is a good idea to put some provisions in place for accidental oil discharges. For plants with storage amounts greater than these OSHA standards, the first step should be to plan for an oil spill.
Preparing for an Oil Spill
A written SPCC plan should address questions such as how will the facility prevent oil contamination to waterways and adjoining shorelines, as well as what practices and preparations will be used to prevent and respond to oil discharges. The EPA does not require the use of specific methods or equipment but allows individual organizations to decide which techniques are appropriate for them. However, plans should be in compliance with Good Engineering Practices (GEPs) and may need to be certified by a professional engineer.
Providing secondary containment for bulk lubricant storage containers should also be considered. This may involve active or passive measures. Active measures are those that require a worker to put something into place before or while work is performed. This could be as simple as covering nearby drains or responding to a spill with a containment kit.
Spill containment kits usually contain absorbent socks, mats, granules, disposal bags and nitrile gloves. These items can be lifesavers until further actions can be taken. Passive measures to oil containment consist of putting and leaving something in place, such as a retaining wall around a large tank or spill containment pallets under totes or drums.
Secondary containment can be divided into two categories: general and specific. General requirements address the most likely discharges from storage and equipment. This would include spills of unknown volumes. Specific requirements target major container failures and focus on size and design. Although the EPA does not define a specific failure volume, it recommends documenting the volumes you choose.
When designing your plan, both secondary containment categories may be employed. In certain cases where secondary containment is not practical, the EPA offers leniency. Additional measures may also be used as long as they are outlined in your plan.
There are several other components of an SPCC plan, such as visual inspections, integrity testing, overfill protection, security measures, training and recordkeeping. A number of companies are available to help you develop your plan. You can also find more information by visiting the OSHA or EPA websites and searching for Title 40 CFR Part 112. Of course, be sure to check your local and state laws, which are usually more stringent than the federal regulations.
The Flammable and Combustible Liquids Code of the National Fire Protection Association (NFPA) is not as stringent for most lubricant users because oils are considered Class IIIB liquids, which have a flash point equal to or greater than 200 degrees F. These flammable and combustible fluid regulations are broken into two classes based on the liquid’s flash point.
Fluids with a flash point of 100 degrees F and above are considered combustible, while those with a flash point below 100 degrees F are considered flammable. These classes also have subcategories with additional limitations based on the flash point and boiling point.
|of plants do not provide secondary containment for bulk lubricant storage containers, based on a recent survey at MachineryLubrication.com
Because petroleum products typically have flash points at or above 200 degrees F, they generally are classified as Class IIIB combustible liquids. However, this does not mean that all oils are grouped into Class IIIB. You will need to read your safety data sheets to determine under which category your lubricant falls. OSHA does not regulate the Class IIIB group but makes suggestions for other classes that can be used for oil storage.
With so many bulk oil storage options on the market, it can be confusing as to which type should be purchased. My advice is to choose the one that boasts contamination control, spill pallets, and color coding.
OilSafe Bulk Systems contribute to 5S, LEAN and TPM improvement initiatives, and assist with addressing OSHA Right-to-Know and other workplace safety and environmental compliance issues.
The Flammable and Combustible Liquids Code also provides ventilation and storage requirements for storage rooms. If you are striving for world-class lubricant storage, this information can help you properly set up your lube room and modernize any outdated practices.
A Proactive Approach
Even if these lubricant storage regulations do not apply to your facility, you should still take a proactive approach. Usually it’s not until an incident occurs that you discover how unprepared your plant actually is. Workers often stand around not doing the right thing or not knowing what to do.
They may grab an absorbent boom or mat to keep oil from spreading, or apply kitty litter to soak up a spill. While it will be easy to see the deficiencies in your plan as you look back on the incident, it’s much better to prevent these spills in the first place.
4 Keys for Better Lubricant Storage
- Develop Training Programs — A training program that notifies workers once and then gets lost in the daily shuffle will not be effective. These programs must be updated and include periodic training for personnel.
- Purchase the Proper Equipment — How can you be prepared if you don’t have the right tools? Having the proper safety equipment can prevent disaster.
- Use Visual Cues in the Field — Walk down key drains that can navigate to waterways, identify them appropriately and share this information with all plant personnel.
- Listen to Personnel on the Plant Floor — These are the individuals who see the flaws within the systems they use every day. Listen to their suggestions and then take action.