Does your Medical Device Company have a compliant SPCC Plan?
Posted on Mon, Mar 29, 2010 @ 01:18 PM
By Todd Kato, Industrial Account Manager
Sometimes, SPCC plans (40 CFR Part 112) are overlooked at medical device facilities. In 2002, the EPA amended the Oil Pollution Prevention Regulation which include requirements for facilities to have active SPCC plans. You may think that there is not capacity for 1,320 gallons of petroleum based products at your facility. However, often areas are overlooked - transformers, elevators, cafeterias with cooking oils, and oils that are often used in lubrication of medical device manufacturing equipment. Remember the keyword is "capacity" for 1,320 gallons or greater of petroleum based products at your facility. Regulations apply regardless of whether tanks or other containers are empty or not full. Your SPCC plan should be reviewed several times a year and amended when any major changes occur at your facility. Take the time to tour your facility, check all outside areas, and check on updated manufacturing processes. It will be beneficial for you in the long run!