Hazmat Training: Spill Kits and OSHA Requirements

UPDATED on Oct. 24, 2024

Most of the time, manufacturers and machine shops won’t even consider buying equipment they don’t expect to use.

Spill kits and other emergency gear are the rare exceptions, items that purchasers hope will never be needed but can’t risk going without.

If a hazardous spill occurs, workplace safety officials realize the kits can hold the line between a temporary crisis and a costly and perhaps even deadly disaster, providing tools to help clean up spills of toxic and corrosive chemicals.

While spill kits aren’t specifically required by the U.S. Occupational Safety and Health Administration, stocking them may help businesses to comply with the workplace safety agency’s myriad rules governing hazardous material handling, cleanup and accident prevention, says equipment supplier New Pig.

Not only do some of those rules mandate the equipment often contained in kits but stocking them can also demonstrate an effort to comply with the agency’s mandate that businesses offer a hazard-free workplace for employees.

“You may be asking yourself if your job site even needs to meet OSHA regulations for hazardous materials,” writes Dan Ketchum for LegalBeagle.com. “If the site contains any material that requires a safety data sheet (SDS) or, really, any liquid that is capable of harming a person or the environment, the answer is a short and resounding yes.”

The Occupational Safety and Health Administration standard that applies is 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER).

Uncontained hazardous substances that are “toxic, flammable or corrosive can cause fires, explosions and pollution of air, water and land,” the agency warns in a pamphlet outlining the rule’s requirements. “Unless hazardous substances are properly treated, stored or disposed of, they will continue to do great harm to living things that contact them.”

There are a variety of spill kits on the market —and we’ll provide details on some of the common types. But first, you’ll want to evaluate a couple of other key items in your facility that will help you select and customize your kits.

4 Critical Questions

1. Are you meeting OSHA Hazard Communication requirements for your shop floor? You need to be sure that you’re labeling chemicals and providing proper signage. That will help avoid a spill by prompting your workers to be cautious, and if one does happen, it will help manage the situation by providing the response team with information it will need for cleanup.

2. How big is your facility? The breadth of the shop floor will help you determine how many kits you should have on hand. The closer the kit is to the locations where chemicals or other hazardous materials are regularly used, the more quickly you can stop the spread of a spill. As each kit’s contents typically can be used only once, you’ll need at least two kits, Ketchum advises.

3. What volumes of chemicals are on site? This information is critical. It lets you identify the capacity and size of the absorbent you will want to stock and will indicate other items with which you can beef up your spill kit to meet specific needs.

4. Who will be on your response team? Have they completed HAZWOPER training? You will need to select and train a team to respond to any spill defined as an “emergency” by OSHA. Its hazardous waste operations rule requires certifications for team members who respond to emergency spills—up to 40 hours of initial training and an annual training refresher. You might choose to have these team members be your spill responders even if an accident is incidental and you have detailed your plans in your hazard communications.

Incidental Spill Kits vs. Emergency Spill Kits

In OSHA parlance, two characteristics define incidental spills: “limited in quantity and posing no significant safety or health hazard to workers in the immediate area.”

The agency uses the example of a pint bottle of xylene in its HAZWOPER guidance for general business.

Read More: How Brady SPC Soaks Up Shop Floor Hazards

An emergency spill requiring compliance with HAZWOPER and necessitating the use of specified equipment, as well as containment and cleanup procedures by trained teams, involves the uncontrolled release of a hazardous substance.

Now, let’s look at some common kits that machine shops and manufacturing plants might need and what items they should contain, according to Legal Beagle and spill-cleanup professionals.