Last month I dealt with questions about a pre-trip technician checklist for vacuum trucks. The discussion brought up another important topic: the spill response plan. While no one wants to deal with an accident or a spill, these mishaps are likely at some point in a pumping operation. As with any other type of accident or incident, they are best handled when the technician or driver has prepared ahead of time. So whether you have one service truck or a large fleet, it’s important to have a spill response plan and make sure everybody knows the details.

Technicians must recognize a spill and emergency conditions and know how to respond. If you are the business owner, you have a responsibility to prepare your crews for an emergency. When they are calling you on their mobile phone after an accident is not the time to be educating them on how to handle a spill situation.

SECURE THE SITE

Business owners are required to provide written spill and emergency plans covering the types of materials being transported. The plans do not need to be exhaustively detailed, but they should spell out the sequence of the spill response and provide the appropriate emergency phone numbers for the type of incident.

Emergency phone numbers should include 911 for injuries on site, an accident involving another vehicle or a fire. The home office number should be readily available because it is the owner’s responsibility to notify regulatory authorities about the incident. It should not be left to the technician in the field to make the calls.

If the incident involves a septage, sewage effluent or sludge spill, the plan should detail how the technician should secure the site. Any discharge of these materials is considered an infectious risk for human health and if it involves surface water, it may create problems for fish and other aquatic wildlife. The area should be physically blocked off, isolating people and animals from the site. If necessary to contain the spill, absorbent mats should be used or temporary dams constructed. In the case of the vacuum truck technician, the truck itself may be the best weapon. The material can be vacuumed into the tank.

REMEMBER THE REGULATORS

Where the spill happens will dictate which regulatory authorities must be contacted. More agencies and entities are involved when the incident occurs on public property over private property. This is one of the main reasons not to leave emergency contacts up to the technician in the field. Significant fines and penalties may come into play if the incidents are not reported in a timely fashion. Lack of reporting usually also creates increased liability for damage caused by the spill.

If the spill is in or directly impacts surface water – whether the spill  started on private property or not – the incident is pushed into the public realm. While definitions of public waters may vary from state to state, in general if the spill enters a lake, stream or wetland, it is considered to impact public water. This will immediately involve the agency charged with overseeing water quality in the state. There may also be specific requirements of how the spill is dealt with. And again, I’ll stress that non-reporting is a serious offense. What needs to be made clear to all technicians is they need to report to the office immediately even if only a small amount of the spill has entered surface water or any catchment (storm sewer) where it will empty to surface water.

The plan and discussions with your crews should focus on which authorities technicians are authorized to talk to and the scope of that communication. For instance, technicians should discuss only what happened in the spill incident and refrain from offering theories about what they think “might” have happened. They need to know an “I do not know” answer is permissible. Larger companies will have someone designated to talk with the media. The spill response plan and the technician should be clear about who responds to media inquiries.

IT’S YOUR TURN

This is a big topic, and I’m certain there are other aspects of spill response planning I haven’t covered. I hope this provides a basis for the discussion of these plans within your companies. I would also enjoy hearing from pumpers who have had direct involvement with spills. We can make some of those experiences part of future articles.