What is Secondary Containment?
Secondary Containment, Housekeeping & Due Diligence
What is “Secondary Containment”?
Secondary Containment is defined in the US Environmental Protection Agency regulations 40 CFR 264.175 as a device or area that prevents hazardous wastes from migrating from their primary storage area. Further, the volume of the secondary containment must be equal to the volume of the largest container being stored, or 10 % of the aggregate volume of containers, whichever is greater. That being said, for all practical purposes a secondary containment product is a “bigger container into which, or onto which, are placed smaller containers” for the purposes of avoiding a nasty cleanup bill if the material were to spill.
Because this regulation that drives secondary containment was written in the mid 1980’s, its language clearly focuses on waste stream materials, or “end of pipe” liquids. Today, the pipe has been followed by through the process to the beginning and, generally speaking, most users of hazardous materials with any regulatory visibility require that these materials be held in secondary containment.
So what does “regulatory visibility” mean & why would someone need Secondary Containment?
Regulatory visibility means that an organization is a known producer of hazardous wastes, user of hazardous materials, has had a cleanup in the past, or has been cited for failure to comply with regulations. Regulatory compliance is a part of the culture of these organizations now, and that’s a good reason to use secondary containment. Spills have to be reported.
Another reason is risk avoidance. The average cost of a spill of hazardous materials is about $25,000. For every spill you prevent, an equal amount is saved. One can prevent dozens and dozens of spills with $25,000 worth of spill containment and spill prevention equipment. Other ways to describe this phenomenon are: risk reduction, cost avoidance, profit protection.
We don’t use hazardous materials so we don’t need secondary containment, right?
Wrong. Just because there are no listed hazardous materials in your plant or process, or no hazardous wastes being generated in your plant, does not mean that secondary containment is not needed. But what you may need isn’t technically secondary containment, but something like it.
That’s where “Housekeeping” comes in. Many liquids used in industrial or work settings today are not “hazardous”. The EPA did a good job of educating business on how to limit their exposure by limiting, or even eliminating, hazardous materials from the workplace. And just who is going to claim that liquid soap, for instance, is hazardous? What we have to be concerned with now is the nature of the hazard, like slip-and-fall injuries.
Slip-and-fall is the #1 lost time injury in the US. The average slip-and-fall injury costs the employer about $25,000 per incident. Liquid soap isn’t a listed hazardous material, but it certainly is hazardous if it is lying on the floor: that’s an accident waiting to happen. And the economics work out about the same as if the material was a real hazardous material. Injuries have to be reported.
Know what is the user really trying to accomplish..
Housekeeping products work pretty much the same as a Secondary Containment product, but may not have the same features, the same liquid volume capacity or the same price point. Identifying the real need is doing Due Diligence.