Ask the Expert, Q&A, Special Topics in Environmental Management

Spill Reporting

Q. Would flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine Spill Prevention, Control, and Countermeasure (SPCC) applicability if they are stored in 55 gallon drums or greater?

A. Under the Spill Prevention, Control, and Countermeasure (SPCC) regulations, the term “oil” is very broad, and includes all kinds of oils, such as animal fats and vegetable oils. The rule also does not define a percentage of oil in a mixture for the purpose of defining if a mixture is an oil for regulatory applicability purposes. Therefore, because you have nut oils as part of a flavoring mixture in drums with a capacity of 55 gallons or greater, and because nut oils are considered “oil” under the SPCC regulations, the entire flavoring mixture you describe that includes such oils as additives is considered to be an oil and you must count the capacity of these drums toward your facility’s aboveground threshold capacity for SPCC purposes.

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