Secondary containment means different things to different people. So it’s understandable that you may be a little confused! The first thing you need is a basic understanding of what secondary containment is. You also need to understand how your secondary containment needs are tied into the specific Environmental Protection Agency (EPA) or Occupational Safety and Health Administration (OSHA) regulation or regulations that apply to your facility.
The 411 on Secondary Containment
Here’s the scenario: Your primary container fails (e.g., a drum/barrel, IBC tote, storage tank — you get the picture). The spill is heading directly toward a drain that connects with the public sewer system. But you’re not too concerned, because your secondary containment stops the spill from spreading. So, basically, secondary containment is any system, device or control measure that is used to stop a discharge from leaving a specified area. The theory is that if a spill can be contained, it will not pollute the environment or cause additional harm. More than a dozen EPA and OSHA regulations require secondary containment, and it is mentioned in several industry standards.
Obviously, a secondary containment system is something you want to have.
What Does Secondary Containment Look Like?
Here’s where it gets a little sticky. Neither the EPA nor OSHA specifies what a secondary containment system must look like. They have guidelines on the spill volume that needs to be contained and what the secondary containment system must be capable of doing, but no specific design, device or product is specified by regulation, because both agencies recognize that each facility will have different scenarios and needs. For small spills, something as simple as absorbents can be used for secondary containment; in other cases you might need a highly engineered system.
So you have the liberty to build, design, install and use whatever type of systems or products you want — as long as they meet the regulated criteria and are truly capable of stopping a discharge from leaving an area.
Who Needs Secondary Containment?
If you store hazardous materials and/or hazardous wastes in your facility, you are likely to need secondary containment systems to meet one or more regulations. OSHA and EPA have very broad definitions of what constitutes a hazardous material. You probably already know if you have hazardous materials onsite, but basically, if it has a Safety Data Sheet (SDS) or it is a liquid that could harm a person or the environment, chances are good that there is a regulation that considers it to be hazardous.
Now, before you get overwhelmed thinking about containment for every single thing in your facility that has a SDS, let’s put things in perspective. That little half-ounce bottle of correction fluid on every desk is hazardous because it contains a flammable liquid. If it spills on someone’s desk, it’ll make a mess, but it’s not likely to enter a floor drain and contaminate a nearby creek. So, chances are good that it won’t need secondary containment. As a rule of thumb, look at the liquids that come in drums and totes, as well as anything that’s stored in bulk tanks, and focus your secondary containment efforts on those areas first.
Bottom line: You want to keep spills out of the environment just like OSHA and EPA do. And you have lots of ways to accomplish that goal. If you’re still not sure about what you need or are confused about regulations, give us a call. New Pig will contain your spills and set your mind at ease.
You tell us: What other questions do you have about secondary containment? Leave a comment below!