EHS Management

Don’t Let Incidental Spills Wreck the Day

Responding to spills is rarely something that is scheduled into anyone’s daily list of tasks. Spills interrupt operations, causing anything from nuisance production delays to citywide evacuations.

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Fortunately, most spills that happen in fixed facilities can be classified as “incidental.” This means that although they may disrupt normal operations, they don’t pose an immediate safety risk to facility personnel, the neighboring community, or the environment.

Facilities that take the time to train employees to recognize and respond to incidental spills can minimize risks to their employees. By stocking appropriate tools and equipment in spill-prone areas, they can also minimize downtime.

Defining Incidental

The Occupational Safety and Health Administration (OSHA) created the hazardous waste operations and emergency response (HAZWOPER) standard to protect several different types of employees, including those who respond to emergency spills in their workplaces. Employees who will take action in the event of an emergency spill must be properly trained to meet the requirements of this standard.

An emergency spill is one that presents a significant safety risk to employees, the community, and/or the environment. Depending on how involved the employee will be during an emergency response, initial training to qualify someone to be an emergency responder can take anywhere from 8 to 40 hours. Annual refreshers are also required so that responders can refresh their knowledge and demonstrate that they still have the skills necessary to protect themselves while responding to emergency spills.

But, when it comes to incidental spills, OSHA allows facilities to incorporate incidental spill response training into other safety trainings, such as hazard communication training. This is permitted because OSHA recognizes that from time to time, things do leak and spill; and every spill is not an emergency. There is no specific time requirement for initial training; and annual refreshers are not required.

One topic that should be covered, however, is how the facility defines “incidental.” In general, an incidental spill is one that can be cleaned up by employees in the work area without external help. Incidental spills are spills that present a low level of risk to the employees who will be responding.

In some cases, the volume of a spill will play a role in determining whether a spill is incidental or an emergency. However, it should not be the sole factor. The hazardous characteristics of chemicals stored and used at the facility, the locations where spills may happen, and employees’ level of training should all be considered when making these decisions.


Being prepared to handle incidental spills can, in some cases, prevent them from becoming emergencies. For example, if a spill can be quickly contained so that it does not enter drains or other sensitive areas; it still needs to be cleaned up, but the threat to the environment or sensitive processes is eliminated. If the liquid is flammable or vaporizes quickly, containing it can also minimize the amount of vapors that become airborne, potentially causing exposure limits to be exceeded. Even in areas where no drains or sensitive areas are present or vapor buildup isn’t a concern, being able to quickly contain and clean up a spill minimizes the risk of a slip-and-fall incident and minimizes the amount of space that will need to be cleaned up.

Stocking spill response supplies, such as absorbents, squeegees, mops, and vacuums in areas where liquids are stored, used, transferred, and collected will allow employees to quickly access them when and where they are most needed.


Training should specifically explain how the facility defines an incidental spill, based on the types of chemicals present, their locations, and the employees’ levels of training. It should also reaffirm that if a spill is an emergency, it needs to be handled by someone with more training.

Even though the risk to employees responding to incidental spills is low, they still need to be taught how to clean up spills correctly and where spill response materials are kept. Take employees to various locations in the facility where response supplies are kept. Demonstrate the proper use of all response items, and allow each employee to practice using them so that when the need arises, they will be more likely to remember what to do.

It is also helpful to teach everyone to report spills, no matter how small. It is very common for employees to clean up a small spill, take care of the spent materials and go on with their day. After two or three such incidents, the response supplies—especially absorbents—quite often have been used and the kit, bin, shelf, or locker where they are kept is empty.

Providing incidental spill response training and stocking absorbents and other supplies that will be needed to respond empowers employees to take care of these spills quickly and efficiently. Incorporating incidental response into job descriptions and establishing protocols for cleaning up spills will help to ensure that the job is done quickly and safely.

Author's nameKaren D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer, and technical writer for New Pig. She has more than 24 years of experience helping EHS professionals find solutions to meet EPA, OSHA, and DOT regulations as well as industry consensus standards. Hamel is a Certified Safety Professional (CSP), OSHA-authorized General Industry Outreach Trainer, Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) Trainer, and hazmat technician. She serves on the Blair County, PA, LEPC and has completed a variety of environmental, safety, emergency response, DOT, and NIMS courses, including Planning Section Chief. She conducts seminars, webinars, and trainings for a variety of national organizations. She can be reached at 800-HOT-HOGS® (468-4647) or by e-mail at