Hazmat Training: What Are OSHA’s Spill Kit Requirements?

Most safety chiefs will tell you that they hope they never have to use their spill kits. That said, OSHA requires that companies do more than buy a couple of kits and tuck them on a shelf. Here’s what you need to know when selecting OSHA-compliant hazmat spill kits.

If you use hazardous chemicals or materials in your facility, then there are three simple rules. You need spill kits—possibly several. You need the right items for the chemicals in your shop. And you need to comply with the government’s regulations for containing and cleaning up spills.

“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).

There are four spill kits for which OSHA provides guidance—and we’ll detail what each must include. 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 Factors Before Choosing a Spill Kit

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 making your workers cautious, but HazCom best practices also help manage a spill after it happens 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 nearer the kit to the locations where chemicals or other hazardous materials are regularly used, the quicker you can stop the spread of a spill.

As each kit’s contents typically are one-time use only, you’ll need at least two kits, Ketchum advises.

3. What volumes of chemicals are on-site?

That information is critical. It lets you identify the capacity and size of the absorbent you will want to stock.

It’s also likely one of the ways you may choose to beef up your spill kit to meet your facility’s 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” in the standard. HAZWOPER 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.

“Incidental spills are the most-common type of spills facilities face,” points out Karen D. Hamel, a regulatory compliance trainer with New Pig, in EHS Today. “An incidental spill does not pose a substantial hazard to the worker or workers cleaning it up.”

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

Now, let’s look at the types of kits metalworking plants might need and what the four OSHA-compliant kits must contain.

Need to perform HAZWOPER training? Look no further. MSC now offers instant compliance training quotes for the Center for Safety and Environmental Management.

Also check out MSC's Safety Guide Book for Spill Containment Solutions.