SPCC Implementation Tips: 10 Practical Lessons for Keeping Plans Effective

EH&S From Experience Newsletter: August 2026

Spill Prevention, Control, and Countermeasure (SPCC) plans are legally required for facilities with an aggregate aboveground oil storage capacity of 1,320 gallons or more. While preparing the plan is an important step, many facilities find that implementation is where the real challenges begin: Staff turnover, competing priorities, and responsibilities shared among multiple departments can make it difficult to keep inspections, training, and documentation on track over time.

Drawing on decades of experience helping facilities develop, update, and implement SPCC plans, Hixson has identified the following 10 practical tips that can help facilities move from having a compliant plan on paper to maintaining a successful program in practice:

1. Clearly identify responsibilities within the SPCC plan. Many facilities have multiple groups involved in SPCC-related activities. Maintenance teams may inspect spill kits, logistics personnel may oversee generators, and third-party vendors may handle equipment inspections. Responsibilities should be clearly identified within the SPCC plan. A facility may choose to maintain a combined SPCC plan for all parties or separate plans for individual parties, but everyone involved should understand their responsibilities and agree on how compliance activities will be managed and recorded
2. Use an electronic Preventive Maintenance (PM) scheduling system to maintain records. One of the most common implementation challenges is gathering documentation from multiple sources. During an inspection, regulators may ask to see generator inspections, spill kit checks, tank inspections, and vendor reports. Electronic PM scheduling systems can be beneficial for maintaining records of inspections and making them easier to retrieve when needed.
3. Streamline spill kit inventory inspections. Spill kit inventory sheets can be taped to the inner lid of the kit for easy reference when checking inventory or locating a specific item. Spill kit inspections can also be streamlined by using tamper-proof tape or fasteners on kit lids, allowing personnel to quickly identify whether a full inventory verification is needed.
4. Clearly mark spill kit locations. Over time, spill kits can migrate away from their designated locations. A sign above the kit or tape on the floor around the kit can help identify its intended location and discourage relocation. These visual indicators also make it easier to recognize when a spill kit is missing.
5. Locate spill kits near the highest spill risks. Spill kits should be positioned within a short travel time to the facility’s highest spill-risk areas. In some cases, a single spill kit may be able to serve two or more risk areas when strategically located.
6. Provide training materials and signage in all applicable languages. If oil-handling employees speak multiple languages, training documentation should be available in all applicable languages to support understanding. Facility signage should also be provided in applicable languages to help improve awareness and response readiness.
7. Understand transformer applicability requirements. Transformers are often overlooked during SPCC evaluations. If a transformer is owned or serviced by the facility, it should be included in the facility’s oil inventory. If a transformer is owned by the utility company and the site already requires an SPCC plan, it is considered a best practice to address transformer inspections and response procedures within the plan. When a utility-owned transformer is the only reason a site exceeds the 1,320-gallon threshold, a plan is not required, but facilities may wish to coordinate with the utility provider to establish communication procedures in the event of a leak.
8. Verify oil content in transformers and other oil-filled equipment. Transformers contain mineral oil for heat transfer, and their oil volume is often underestimated. If capacity information is unavailable, a manufacturer’s specification sheet can be used to estimate oil capacity based on the unit’s kVA rating. Other oil-filled equipment, including balers, and ammonia compressor systems, should also be evaluated and accounted for within the SPCC program, as applicable.
9. Consider practical containment solutions. Not every application requires a large containment structure. Facilities have successfully used rubber berms around balers or near exit points to improve containment. Similarly, drip pans can be effective for collecting hydraulic oil from slow leaks on older ammonia compressors. These simple measures can help prevent releases from reaching the environment.
10. Don’t overlook emergency contacts and long-term inspection requirements. Contact lists can be posted in offices and break rooms for quick access to facility management and key personnel during a spill event. In addition, because formal tank integrity inspections often occur only every five to twenty years, installing a sign on the tank showing the next required inspection date can help prevent important compliance milestones from being missed.

Implementing an SPCC plan doesn’t have to be complicated. Clear responsibilities, organized records, practical inspection strategies, and thoughtful employee training can help facilities maintain compliance while strengthening their overall spill prevention program.