Does your site have appropriate spill response equipment? Does the spill kit contain everything it's supposed to? Is the spill kit accessible? In this article, we look at when a spill kit is required, what it should include, where it should be located, and how it needs to be maintained.
This article is general information only. For expert advice specific to your needs, get in touch.
In Western Australia, the legal requirements for spill response equipment come from the Dangerous Goods Safety (Storage and Handling of Non-Explosives) Regulations 2007. Regulation 48 requires a site to have a documented Dangerous Goods Risk Assessment which must address the risk associated with loss of containment through spills or leaks. If that risk assessment requires spill response equipment, then under regulation 74 the operator then must ensure that the spill response equipment is provided and is:
"kept at the site; and
properly maintained; and
accessible at all times to persons at the site."
There is also a legal requirement to clean up spills or leaks as soon as practicable under subregulation 51(2).
When asked what a spill kit should include, we generally say:
"All the necessary equipment to capture, clean up and dispose of a spill safely"
Capture - stop the spill/leak from spreading further
Portable bunding such as booms
Absorbent material (pads and loose materials)
Drain covers and plugs
Larger sealed containers to put leaking packages inside
Clean Up - remove the spilled / leaking product
Portable pumps or decanting equipment
Dispose - treat and/or remove contaminated materials in accordance with environmental regulations and best practice
Sealable container(s) suitable to hold spilled product or contaminated items until disposal
Means of treatment of spills such as an oily water separator
Neutralisers / other substances to render the spilled chemical inert
Safely - without undue risk to people responding to the spill
Personal Protective Equipment(PPE) as recommended by the safety data sheets (SDS) for the products(s) which could be spilled.
All equipment used in the spill response to be compatible with the substance(s) being cleaned up. E.g. using equipment that is not a source of ignition when cleaning up flammable liquids.
Some other things to consider include:
Check the relevant standards or industry guidelines for the products being stored. E.g. Section 9.4.2 from AS 1940:2017 for flammable and combustible liquids.
Consider what the spill response team will need to follow your spill response plan. E.g. if there is more than one member of the spill response team, multiple sets of PPE will be required.
There are many pre-made spill kits that may or may not be suitable for the products in question.
The spill response equipment should be clearly identifiable. Many pre-made spill kits come in a bright yellow container with a clearly visible "Spill Kit" label.
The ideal location for a spill kit will be:
close to the likely location of a spill
clearly visible from the likely location of a spill occurring
clear of obstructions or trip hazards
not locked away
If there is no suitable or safe location close to the area where spills are likely to occur, a dangerous goods risk assessment may be able to select an alternative.
The location of the spill kit needs to be marked on the site plan. Cadre also recommend the use of signage to clearly identify the location of the spill kit.
A spill response kit needs to be included in the inspection and maintenance procedures for a facility.
What should we check?
An inspection of the spill kit should include the following as a minimum:
Any equipment missing or requiring replacement
Any equipment expired?
Is the spill kit still in a readily accessible location?
Is the spill kit clearly visible?
Is the spill kit contain objects that shouldn't be in the spill kit?
Has the spill kit been used? does any of the equipment need replacing?
How often should we check the spill kit?
This depends on how often the spill kit is used and how active the site is. Refer to the site dangerous goods risk assessment and consider the following:
A detailed inspection as part of the site fire extinguisher testing (every 6 months)
A brief check of the spill kit as part of daily safety inspections (for rubbish, blocked access etc.)
A brief check of the spill kit before a transfer is commenced to ensure all required equipment is available.
Include post-incident replenishing of the spill kit as part of the Emergency Response Plan
How do we stop people putting objects in front of the spill kit?
The importance of spill kits should be included in company training policies and inductions. It may help to have a clear line painted on the ground showing the accessway to be kept clear.
How do we stop people from using the spill kit as a rubbish bin?
Again it is important to include spill kit awareness in site training and inductions. Ensure that your spill kit is clearly labeled (this may mean a label on the front and top of the spill kit). In addition, an easy-break cable tie or lid cover could be used as a physical reminder to personnel.
Not sure what spill response equipment you need? Do you know what you will be doing in response to a spill? Contact us to have your spill response plan and equipment reviewed by a dangerous goods consultant accredited by the Department of Mines, Industrial Regulation and Safety. You can also find out more about dangerous goods safety by reading some of our other blog articles.
This article was prepared as general guidance only and based on information current at time of publication. The use of this information is at the reader's own risk, Cadre Engineering accepts no liability for any outcomes of following this guidance. For expert advice, specific to your needs, please get in touch.