Tuesday, May 11, 2010

Regulation of Milk Under SPCC Rule 40 CFR 112

The storage of "oils" regulated under the federal SPCC Rule (40 CFR 112) includes materials well outside the traditional lubricants and fuels. Many food grade oils, fats, cooking oils, etc are regulated and require spill prevention and controls. Even liquids that contain even small amounts fats or oils in a mixture can be regulated.

Many facilities are surprised to learn that milk is also regulated under SPCC Rules. In 2009, US EPA proposed a rule to exempt milk from SPCC Rules; however, to date this proposed exemption has not been promulgated. Currently, it is assumed that in 2010 US EPA will again propose amendments to 40 CFR 112 to address milk. Milk can also be regulated as a potential pollutant if spilled, and be subject to spill notification requirements outside of regulation under 40 CFR 112.

Example: Minnesota spill reporting requirements

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