Karen Hamel quote

Not every spill is an emergency

by Karen Hamel

Facilities must be prepared to handle worst-case-scenario spills.  In addition, anyone engaged in emergency spill response operations must be trained to meet the requirements of OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard.

But the simple truth is that worst-case scenario spills don’t happen every day, and most spills—although inconvenient—are not emergencies.  Incidental spills are common in facilities— sometimes daily or even multiple times during a shift.   Training employees to handle these nonemergency spills can help improve safety and minimize downtime.

Emergency or incidental?

OSHA’s HAZWOPER standard helps ensure that anyone responding to emergency spills has the training and skills necessary to stay safe during response operations.  OSHA’s definition of an “emergency spill” includes situations that:

  • Require evacuation of an area to ensure health or safety;
  • Create Immediately Dangerous to Life and Health (IDLH), fire, explosion, or other hazardous conditions; or
  • Require immediate action to avert danger.

In addition to initial training, which ranges from a minimum of 8 to over 40 hours of instruction, annual refresher training are required for responders to maintain their skill sets.

By contrast, incidental spills are spills that do not pose a significant safety or health risk.  They are limited in quantity and don’t have the potential to become an emergency within a short period.   OSHA makes it clear that volume is not the sole factor in determining whether a spill is incidental or an emergency—other factors must also be considered.

Response to incidental spills is not governed under HAZWOPER, giving employers the liberty to incorporate incidental spill response into standard operating procedures or other safety training.

Evaluating spill hazards

Spills can present unique safety hazards that don’t exist during normal operations.  Like all safety hazards, spill scenarios must be evaluated so that employees can be properly trained to protect themselves and, when appropriate, know how to clean up incidental spills safely.  Evaluating hazards also helps employers and safety managers establish parameters for what factors constitute an emergency.


When evaluating spill hazards, it is important to look for ways to simplify incidental spill response training without sacrificing safety.    For example, in facilities with a wide variety of chemicals, developing different response procedures for each chemical is likely to result in failure because it will be difficult for employees to remember multiple procedures—especially when each procedure is (hopefully) not used daily.

Establishing guidelines can help simplify training.  For chemicals that have been determined to have a low health hazard, some facilities can use volume as the determining factor for what is deemed to be incidental:  Clean up spills less than “x” gallons; call the spill response team for larger spills.

Some facilities use the “step-over” rule: If you can step over it, clean it up.  If you can’t, call the spill response team.  Still others group chemicals into categories:  Clean up spills of anything on list “A”; call the spill team for anything on list “B.”  In addition to establishing guidelines for determining if a spill is incidental or an emergency, employees also must be taught how to use response equipment and who to report to after a spill has been handled.

Don't miss Hamel speak at BLR Safety Summit 2015 this April. Learn more about her session,  Responding to Spills without HAZWOPER: Training Employees to Clean up Incidental Spills Safely.

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