Spill Prevention, Control, and Countermeasure (SPCC) Plans are required for facilities that store large quantities of oil and oil‑based products. They're meant to prevent oil discharges into navigable waters or adjoining shorelines—a serious environmental threat that can lead to massive cleanup costs, legal violations, and reputational damage.
Yet even though SPCC Plans are a federal requirement, we still regularly see plans that fall short in ways that could have real‑world consequences. Whether it’s out of laziness or ignorance, many facilities are unknowingly out of compliance.
As environmental consultants, we’ve been in the field and seen it all—outdated binders collecting dust, broken containment berms, and employees who have no idea what an SPCC Plan even is. These aren’t just technicalities. They’re red flags that could land your facility in serious trouble during an inspection or emergency.
If you're unsure whether your SPCC Plan is up to par, don’t wait for a problem to arise. Contact us here and let’s make sure your plan isn’t putting your business at risk.
Let’s walk through the most common SPCC Plan issues we encounter—and why they’re such a big deal. Each one has the potential to trigger a violation, delay response during a spill, or fail to protect your site and the environment.
This one’s simple: If your facility meets the threshold (1,320 gallons of oil aboveground or 42,000 gallons underground), you're required by federal law to have an SPCC Plan. And not just any plan—it must be site‑specific, accurate, and certified by a Professional Engineer (for most facilities).
We’ve encountered facilities that “have” an SPCC Plan, but it’s missing key sections, still contains another facility’s name, or was cobbled together from an online template without any customization. Worse, some businesses don’t have a plan at all, assuming it doesn’t apply to them. This is a major compliance risk that can result in serious fines and enforcement actions.
👉 If you’re not sure whether your plan meets regulatory requirements, reach out now for a quick review.
SPCC Plans must be reviewed and updated every five years —or sooner if changes are made at your facility (new tanks, removed equipment, site layout changes, etc.). But in practice, many facilities go years without touching the plan. Staff turnover, reorganizations, or plain old forgetfulness can cause updates to fall through the cracks.
We’ve seen SPCC Plans that reference tanks that were removed years ago, omit new equipment, or include names and phone numbers of employees who haven’t worked there in ages. In an emergency, this kind of outdated info can stall your response and result in non‑compliance enforcement actions like fines or worse.
📅 If your SPCC Plan hasn't been updated recently, it's time to fix that. Let’s help you update it.
Recordkeeping is one of the most misunderstood—but heavily scrutinized—parts of SPCC compliance. Facilities are required to maintain documentation of:
Yet, at many sites, these records are either missing entirely or hastily filled out right before an inspection. Regulators know what this looks like—and they’ll call it out. Beyond that, if a spill does happen and you don’t have records showing that you were inspecting and maintaining your systems, your liability skyrockets.
📁 Not sure if your recordkeeping system would hold up to scrutiny? We can audit it with you.
It’s one thing to say you’re prepared for a spill—it’s another to actually be prepared. Your plan should list what spill response equipment is needed on‑site (like absorbent socks, booms, PPE, etc.), and that equipment must be present, accessible, and in usable condition.
We often find dusty, half‑empty kits shoved in corners or locked in rooms no one has access to. In a real spill, every second counts—and if your staff can’t find or use what they need, the damage will escalate quickly. So, be sure you have a spill kit, you know what's in it, you know how to use it, and it's reflected in your SPCC plan.
🚨 Spill kits and response tools are your first line of defense. Let us help evaluate your readiness.
If you walk around your site and see oil stains on the ground, sheens in storm drains, or cracked containment areas—and your SPCC Plan doesn’t address them—that’s a problem. These are clear signs that your spill prevention program is not being implemented or enforced.
Unaddressed stains or leaks can be considered evidence of actual discharges, and the EPA and other regulators take that seriously. Inspectors will assume that if you're not cleaning up small leaks, you're probably not ready for a big one either.
👀 If there are visible signs of trouble, it's time for a real assessment. Book an inspection with us today.
This is one of the most critical—and commonly mishandled—SPCC requirements. Each oil storage container must have adequate secondary containment that can hold the full volume of the container plus freeboard for rainfall (if it's outdoors). But we often see:
None of these situations are compliant, and they can render your entire plan meaningless in the eyes of an inspector—or in the middle of a spill event.
🌧️ Containment issues are low‑hanging fruit for enforcement. Let us help fix them fast.
This is a surprisingly common issue: your employees are the first responders in the event of a spill, yet many don’t know what the SPCC Plan is, what it contains, or what their responsibilities are.
We’ve asked simple questions on‑site like “Where’s your SPCC Plan kept?” or “Do you know where the nearest spill kit is?” and gotten blank stares. That’s a huge red flag. Annual SPCC training is required, and your staff must understand how to respond effectively.
And "not knowing how to train" is no excuse, since you can even take online SPCC training these days.
👷 If your team isn't trained, your plan isn't effective. Ask us about SPCC training options here.
Overlooking these seemingly small issues isn’t just about failing an inspection. It’s about:
Environmental damage from spills that could have been prevented
Fines and legal action for non‑compliance
Delays in operations while issues are addressed
Reputational damage with customers, stakeholders, or the community
SPCC Plans are meant to protect your business as much as they protect the environment. But they only work if they’re done right, kept current, and taken seriously.
At the end of the day, your SPCC Plan isn’t just a regulatory requirement—it’s a tool designed to protect your people, your property, and the environment. But it only works if it’s accurate, maintained, and actually implemented. The issues we’ve highlighted here may seem minor, but in our experience, they’re exactly what regulators notice—and what can quickly spiral into costly violations.
Whether your plan is outdated, missing details, or gathering dust in a binder no one touches, the time to fix it is now. A small investment in reviewing and updating your SPCC Plan can save you major headaches down the road.
If you’re ready to take a fresh look at your SPCC compliance—or you’re just not sure where you stand—we’re here to help. At RMA, we work with businesses like yours every day to make environmental compliance easier, clearer, and less stressful.
✅ Let’s make sure your SPCC Plan is doing what it’s supposed to.
Contact us today for expert guidance and practical solutions that actually work in the field.