Understanding EPA & OSHA Secondary Containment Regulations

rows of chemical containers on pallets

Secondary containment systems are essential for ensuring the safety of workers and the environment in various industries that handle hazardous materials, chemicals, and waste. These systems are designed to contain spills, leaks, or the release of these materials, preventing them from spreading and causing harm to people, wildlife, or the ecosystem.

A secondary containment system typically consists of a barrier or containment structure that surrounds or holds the primary container or equipment. It is designed to hold any spilled or leaked material, allowing for easy cleanup and preventing contamination of the surrounding area.

In this article, we will provide a comprehensive guide to understanding EPA and OSHA regulations on secondary containment. We will discuss the importance of this system in preventing environmental and worker hazards, the different types of containment systems, and the criteria for selecting and designing effective.
Understanding Secondary Containment
Different industries use different secondary containment systems, depending on their specific needs.

Types of Secondary Containment Systems

  • Berms: Typically made of a flexible or rigid material, berms are used to contain liquids in a designated area to prevent them from spreading to other parts of a facility. They can be temporary or permanent and are often used for spill response or to contain leaks from stationary equipment.
  • Drip Pans: Drip pans are small containers placed under equipment or containers to catch leaks or drips. They are often made of metal or plastic and can be easily cleaned or disposed of after use.
  • Double-Walled Tanks: Double-walled tanks consist of an inner and outer tank, with a space between them that is monitored for leaks. They are commonly used for storing hazardous liquids, such as fuel or chemicals, and are often required by regulations.
  • Spill Pallets: Spill pallets are platforms with a built-in sump that can contain spills from drums or other containers. They are often used for temporary storage and are available in various sizes and materials.

Who Needs Secondary Containment?

  • Facilities that Handle Hazardous Materials: Any facility that handles hazardous materials, such as chemical plants, manufacturing facilities, and laboratories, are required to have secondary containment systems to prevent leaks or spills from causing harm to workers or the environment.
  • Transportation Companies: Companies that transport hazardous materials are also required to have secondary containment measures in place, such as spill kits or containment systems on their vehicles.
  • Farms and Agricultural Facilities: Farms and agricultural facilities that store or handle fuels, pesticides, or other hazardous materials may also need secondary containment to prevent contamination of soil or water sources.

EPA Regulations on Secondary Containment

EPA regulations on secondary containment aim to protect human health and the environment by preventing the release of hazardous materials into the air, water, or soil.

Applicable EPA Regulations and Standards

  • The Resource Conservation and Recovery Act (RCRA) sets the federal requirements for hazardous waste management, including secondary containment. RCRA regulations require facilities to have secondary containment measures for hazardous waste containers, tanks, and containment buildings.
  • The Spill Prevention, Control, and Countermeasure (SPCC) rule applies to facilities that store or handle oil, including petroleum products, and requires them to have a written plan for preventing spills and managing containment systems.
  • Other EPA regulations, such as the Clean Water Act and Clean Air Act, may also require secondary containment measures for certain types of facilities or operations.

Criteria for Selecting and Designing Secondary Containment Systems

  • Secondary containment systems must be designed to contain the entire volume of the primary container or equipment in the event of a leak or spill.
  • The containment system should be made of materials that are compatible with the hazardous material being contained and resistant to corrosion, puncture, or other types of damage.
  • The system should also be designed to allow for easy inspection, maintenance, and repair.

OSHA Regulations on Secondary Containment

OSHA regulations require employers to provide a safe working environment for their employees, including measures to prevent spills, leaks, and other hazardous situations. Here are some key points to consider regarding OSHA regulations on secondary containment:

Applicable OSHA Regulations and Standards

  • OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard applies to employees who are involved in cleaning up hazardous waste, spills, or leaks. This standard requires employers to provide appropriate containment and spill response measures to protect workers.
  • OSHA's General Duty Clause requires employers to identify and address workplace hazards that could cause injury or illness to workers, including spills or leaks of hazardous materials.

Criteria for Selecting and Designing Secondary Containment Systems

OSHA requires employers to select and design secondary containment systems based on the potential hazards associated with the materials being stored or handled.
The secondary containment system should be able to contain the entire volume of the primary container or equipment in the event of a leak or spill.
Employers must ensure that the containment system is made of materials that are compatible with the hazardous material being contained and resistant to corrosion, puncture, or other types of damage.

Training and Education for Secondary Containment

Training and education are essential for workers and operators who are involved in handling hazardous materials and using secondary containment systems. Proper training can help prevent workplace accidents and injuries, as well as minimize the environmental impact of hazardous materials

With secondary containment training and education, consider these two main points:

Content and Delivery of Training Programs

  • Training programs should be tailored to the specific needs of the workers and operators and should cover topics such as the types of hazardous materials being handled, the characteristics of secondary containment systems, and the proper use and maintenance of such systems.
  • Training programs can be delivered through a variety of methods, such as classroom instruction, online courses, on-the-job training, or a combination of these methods.
  • Training programs should be reviewed and updated regularly to ensure they remain relevant and effective.

Compliance with Training Requirements

  • Employers are responsible for providing adequate training and education to their workers and operators on the proper use and maintenance of secondary containment systems.
  • OSHA and EPA regulations may have specific requirements for training and education, and employers must ensure that they comply with these requirements.
  • Employers should keep records of training and education provided to their workers and operators to demonstrate compliance with regulatory requirements.
Secondary containment systems are a critical component of preventing environmental and worker hazards associated with the handling and storage of hazardous materials. Ensuring proper design, selection, installation, and maintenance of secondary containment systems, along with providing adequate training and education to workers and operators, while keeping the EPA and OSHA regulations and standards in mind, is essential for maintaining compliance and minimizing the risk of accidents and spills.

The material provided in this article is for general information purposes only. It is not intended to replace professional/legal advice or substitute government regulations, industry standards, or other requirements specific to any business/activity. While we made sure to provide accurate and reliable information, we make no representation that the details or sources are up-to-date, complete or remain available. Readers should consult with an industrial safety expert, qualified professional, or attorney for any specific concerns and questions.


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Author: Herbert Post

Born in the Philadelphia area and raised in Houston by a family who was predominately employed in heavy manufacturing. Herb took a liking to factory processes and later safety compliance where he has spent the last 13 years facilitating best practices and teaching updated regulations. He is married with two children and a St Bernard named Jose. Herb is a self-described compliance geek. When he isn’t studying safety reports and regulatory interpretations he enjoys racquetball and watching his favorite football team, the Dallas Cowboys.