Tracking Spills as an Environmental Aspect

C

canmatrix

Hi,

If spills of hydraulic fluid, fuel, etc. has been identified as an environmental aspect. How would a person go about tracking spills? Does anyone know if a good classification for spills (Major, moderate, minor, etc.)? Any advice would be greatly appreciated.
 

Randy

Super Moderator
Look at what are classified as reportable under the regulations governing you...Classify a legally required reportable level as Major/Large/Big/ or whatever...anything less as minor/small/negligable whatever.....

Pretty common method I've seen in the US, Canada and a couple other places.

Always research the laws you have to comply with and have your tracking, reporting and actions mirror what they state. Any way else muddies up the water
 
R

rickmcq

Hi,

If spills of hydraulic fluid, fuel, etc. has been identified as an environmental aspect. How would a person go about tracking spills? Does anyone know if a good classification for spills (Major, moderate, minor, etc.)? Any advice would be greatly appreciated.

Think about this:

Any spill that can be cleaned up by the employee at the spill site is incidental and not tracked.

Any spill that can be cleaned up by the employee with the help anyone from the maintenance department is not tracked.

Any spill that requires outside help or the activation of your Hazwoper trained personnel, if you have any, to clean up is tracked.

Make a note in your aspect list that incidental spills are excluded from tracking.

Rick
 

Randy

Super Moderator
Think about this:

Any spill that can be cleaned up by the employee at the spill site is incidental and not tracked.

Any spill that can be cleaned up by the employee with the help anyone from the maintenance department is not tracked.

Any spill that requires outside help or the activation of your Hazwoper trained personnel, if you have any, to clean up is tracked.

Make a note in your aspect list that incidental spills are excluded from tracking.

Rick

You follow this guidance in the wrong location and you could wind up with a gazillion $'s in fines and litigation against you that could take a millenia to clear...
 
R

rickmcq

You follow this guidance in the wrong location and you could wind up with a gazillion $'s in fines and litigation against you that could take a millenia to clear...

That's true. That is why I did not say "Follow this and you won't go wrong".

Too many people regulate themselves into oblivion and get into just as much trouble with 2nd and 3rd party auditors only without the fines. I understood the question as wanting a little input on how to set up his 14001 environmental system. Satisfying the requirements of 14001 and government regulations are two entirely different issues.

He should be setting up his aspects based on where the spill occurs as well as the substance and the surface the spill is on. If it's 2 gallons of hydraulic fluid in a work area with a concrete surface that is 50 feet from a drain I wouldn't put it on the list as a significant aspect that needs to be tracked. Throw floor dry on it and dispose of it as universal waste.

Use common sense and not one big all encompassing rule that will cost more time and money documenting a minor spill, especially one that has no legal ramifications if handled right.

Rick
 
M

Michael.Anishton

I can say that you should still "at least" track minor spills that occur. Ensure that you are able to list all major and minor occurrences of spill. Perhaps, there are times that you might use such minor reports to support other major incidental spill claims - so I can say it is somehow important to track those. But of course, there should be a determining factor that would show how minor such occurrences are and action items to be done to avoid minor problems that may lead to major head aches.
 
C

canmatrix

Thanks Gents,

Legislation pertaining to my province dictates that all spills be reported to the government agency regardless of size if there is an interaction between the natural environment and the spilled substance.

I want to track spills so that I can assess the effectiveness of my spills prevention and response program that I have developed for my company. How else to assess whether or not my program is working?
 

Randy

Super Moderator
Thanks Gents,

Legislation pertaining to my province dictates that all spills be reported to the government agency regardless of size if there is an interaction between the natural environment and the spilled substance.

I want to track spills so that I can assess the effectiveness of my spills prevention and response program that I have developed for my company. How else to assess whether or not my program is working?

If you get a knock on the door by your regulator wanting to talk about dead fish in a creek next to your facility you can probably bet the program has a problem...:lol:

Seriously, I had the same thing going on 20 years ago and tracking all spills, developing a baseline and then looking for improvement is about the best way. At one time if we didn't have at least a 10 gallon fuel spill every day we would have to check to see if anyone was working (had a 25,000 gallon spill once, it was exciting)
 
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