Choosing a SPCC - Spill Prevention Control and Countermeasure Plan

2011 © By Roy Blizzard III

In my article, “The Real Purpose of an SPCC”, I described how you should look at a SPCC Plan in relation to your business operations. In this article I’d like to address the common mistakes people make when choosing a company to produce their SPCC’s.

The first rule of thumb in choosing a company is not to choose one based on price alone as there is a huge difference between the price of a plan and the true cost in relation to your business. For example; would you as a business owner purposefully pay good money for outdated or broken equipment? Of course not. So why would you want to pay good money for substandard environmental work or reports? Just because an Oil or Gas SPCC, or a marina SPCC etc., are cheap doesn’t mean you will get your money’s worth from them. But on the other hand, why pay 3,500.00 for a plan of lesser quality than a plan for 500.00 just because the Environmental Company is large and “reputable”. Ask to see examples of their work and have them explain to you why they should be chosen over any other company.

The other rule is be skeptical of a pay money down plan. If a company can’t produce your work, why would you jeopardize your cash flow? I know personally of several companies who have done this and lost thousands when they chose a company based on price alone. They paid up front and the company disappeared with their cash. While I have accepted a small down payment to cover some of my out of pocket expenses when doing field work, I’ve never demanded payment first.

The third rule is to not believe all the “guarantees” the company makes about how reliable their SPCC or environmental reports are or how they will pay for any “deficiency” found in their plan that results in a fine etc. These are all bogus claims to draw you in with a false sense of security on the quality of their environmental reports. The fact is that when you as an owner or operator of a regulated facility under CFR 40, 112, The Clean Water Act, take possession of the SPCC or other plan such as the ERP, FRP, Phase 1 or Phase 2, etc., YOU become responsible for ALL its content when you sign on the dotted line. You become responsible for any and all deficiencies in those plans, not the engineer, because you have sworn so on the certification pages. The only type of guarantee I can make you is that I will guarantee the integrity of my reports, that they are complete and will enable you to implement those reports to hopefully allow you to meet what is called, “best industry standards”.

The fourth rule is what I would call, “investigative procedures”. Look at the background of the company and its owners. There is one company in particular where the owner has been in jail twice for oil field theft and has lost a million dollar + lawsuit for slander and just changes the name of its company when they get in hot water and yet people still waste money with this company due to lack of due diligence research on the company. Choose wisely because it’s your hard earned money on the line.

The fifth rule is one that I call, “Ripeness of Work”. Many so called SPCC mills are using plans so far out of date or so incomplete as to render them useless and worthless for your company in maintaining the security and value of your company. Plans and reports should be re-evaluated several times a year to keep up with all the changing Governmental rules. How do you know the difference between a new plan and an old one? The fact is you won’t until an accident or oil spill happens or the EPA, Texas Railroad Commission or other governmental agency comes calling.

The sixth rule is just simply make sure they are insured so if they cause damage or are injured, you aren’t responsible.

While there are other company issues such as trust, honesty, integrity, friendship, etc these are developed in the ongoing working relationship. Feel free to contact us at T.I.H. Environmental, LLC anytime for more information. www.tihenvironmental.com

For training issues read the article "Are You Prepared for an SPCC Plan Inspection?" at http://tihenvironmental.com/Training.html