Safety & Loss Prevention
SPCC Plan Changes
What do I do when personnel listed in the SPCC Plan change (or other non-technical Plan changes)?
Changes of a non-technical nature, such as a change in personnel listed in the plan, change in phone numbers, etc., should be noted in your campus SPCC plan by simply crossing out the outdated information and writing in the correct information by hand. Certification of a professional engineer (PE) is needed only for technical changes, such as those that would “materially affect the facility's potential to discharge oil.”
[Note — Changes to your campus facilities of a technical nature (e.g., addition of tanks) should be added to your plan and require PE certification.]
Below are further comments on this matter by the EPA.
Comments on non-technical amendments to SPCC plans as published in the Federal Register, July 17, 2002
67 FR 47093
Section 112.5(c)—PE Certification of Technical Amendments …
We believe that PE certification is necessary for any technical amendment that requires the application of good engineering practice. We believe that the value of such certification justifies the cost, in that good engineering practice is essential to help prevent discharges. Therefore, we have amended the rule to require PE certification for technical changes only. Non-technical changes not requiring the exercise of good engineering practice do not require PE certification. Such non-technical changes include but are not limited to such items as: changes to the contact list; more stringent requirements for stormwater discharges to comply with NPDES rules; phone numbers; product changes if the new product is compatible with conditions in the existing tank and secondary containment; and, any other changes which do not materially affect the facility's potential to discharge oil. If the owner or operator is not sure whether the change is technical or non-technical, he should have it certified.
Updated March 14, 2006.
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This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice. (Click here to read full legal disclaimer.)