Most compliance documents have one question about signatures, and it is settled on the day the document is created: this is who signs it, and that is that. An SPCC plan is unusual because the answer is provisional. Whether you are allowed to certify your own plan, or must have a licensed Professional Engineer do it, depends on facts about your facility that can change — and one of those facts is a history of small discharges nobody logged as significant at the time.
The rule itself is straightforward enough to state. A facility that stores oil above certain capacities, and that could reasonably be expected to discharge it into navigable waters, has to prepare and implement a written Spill Prevention, Control, and Countermeasure plan describing its containment, inspections, training and response arrangements. Smaller facilities that meet the qualifying criteria may self-certify that plan. Everyone else needs a Professional Engineer to review and certify it, and until that happens the plan does not count for anything.
What makes it worth holding as a set of dates rather than a document in a binder is what sits underneath that. The plan must be reviewed at least every five years, and the five years run from the day the facility became subject to the rule rather than from the day anyone wrote the plan — a date that, at a site which crossed the capacity threshold by buying drums, may never have been written down at all. Any change to the facility that materially affects the potential for a discharge starts a six-month deadline to prepare an amendment, and preparing it starts a second six-month deadline to implement it. And the eligibility to self-certify is measured over a rolling three-year look-back taken from whatever date you next sign, which means it can lapse quietly and, just as quietly, come back.
None of that generates a letter. There is no register that tells a facility it became subject, no notice when a run of small discharges disqualifies it from signing its own plan, and no acknowledgement when the passage of time makes it eligible again. Here is how the SPCC rule works to track, and how to keep a plan current, implemented, and signed by someone the rule actually accepts.
General information, not environmental, engineering, EHS or legal advice. States and localities can impose additional oil-storage requirements — confirm what applies to your site at the official sources in section 11 and with your state agency.
1. What is an SPCC plan?
The SPCC rule sits at 40 CFR Part 112, made under section 311 of the Clean Water Act. It applies to non-transportation-related onshore and offshore facilities that handle, store or use oil and that, because of where they sit, could reasonably be expected to discharge it into navigable waters or adjoining shorelines. A covered facility must prepare in writing and implement a Spill Prevention, Control, and Countermeasure plan — the containment around its containers, the inspections and testing it performs, the training its staff receive, and what it will do if oil escapes. Remindax helps you hold the review, amendment and certification dates for that plan and reminds the people responsible; it doesn't write, review, certify or amend plans, inspect facilities, or provide engineering, EHS or environmental consulting services.
Two features make the SPCC plan behave differently from most of the documents on this site. The first is that it is not issued to you by anybody. There is no application, no permit number, no expiry printed on a certificate — the obligation attaches to your facility by operation of the rule, and the only artifact is the plan you produced yourself. The second is that the signature on it is conditional. A plan certified by the wrong party is not a slightly weaker plan; under the rule a plan needs the required certification to be effective at all.
Because an oil-storage facility rarely carries this obligation alone — there are usually permits, inspections, training records and reporting deadlines around it — the SPCC dates belong in the same register as everything else the site owes, which is what compliance tracking software is for: tracking and reminders, not a GRC suite.
1.1 Who is allowed to certify the plan
This is the part that decides how much of the work is yours and how much has to be bought, and it turns on two facts about the facility rather than on any choice you make:
- →A Tier II qualified facility may self-certify. That means 10,000 US gallons or less of aggregate aboveground oil storage capacity, plus a discharge history that meets the rule's criteria. The owner or operator signs a set of statements in the plan itself: that they are familiar with the requirements, have visited and examined the facility, prepared the plan to accepted industry practice, established inspection and testing procedures, and will fully implement it.
- →A Tier I qualified facility is a Tier II facility with a smaller largest container. Tier I is not a separate route — it is the same criteria plus one more: no individual aboveground container larger than 5,000 gallons. The reward for staying under that line is EPA's Appendix G template, which, completed and signed, may be used as the plan.
- →Everyone else needs a licensed Professional Engineer. The PE attests that they are familiar with the rule, that they or their agent have visited and examined the facility, that the plan follows good engineering practice, that inspection and testing procedures are established, and that the plan is adequate for the facility. That certification does not transfer responsibility — the rule is explicit that it in no way relieves the owner or operator of the duty to prepare and fully implement the plan.
- →Even a self-certified plan can need a PE for parts of it. A qualified facility may not self-certify alternative measures offered as environmentally equivalent, or a determination that secondary containment is impracticable. Those specific provisions have to be reviewed and certified in writing by a Professional Engineer, which produces a plan with two signatures on different pages and, in practice, two things to keep track of.
Self-certification reads like the light-touch option, and on cost it is. On personal involvement it is the opposite. The Professional Engineer's certification allows the site visit and examination to be carried out by the engineer or their agent. The self-certification does not: EPA's guidance is that where the owner or operator self-certifies, the owner or operator must personally conduct the site visit and facility examination, and there is no provision for an agent or an employee to do it for them. So the route that avoids hiring an engineer is the route that requires a specific named person to walk the site themselves — which is worth knowing when the reminder is being addressed, because a prompt that lands in a shared inbox has not reached anyone who can act on it.
1.2 A tier set by size, and a tier that can be taken away
A tiered obligation that splits between self-assessment and an outside assessor is not new on this site, and it is worth saying plainly where this page sits against the closest one. PCI DSS validation also has levels, and it also divides between a self-assessment questionnaire and an assessor-led report, with the line drawn by card volume. That tier is a fact about the business that its own reporting already tells it. It moves slowly, in one direction, for reasons anyone in finance can see coming a year out.
The SPCC tier does not behave that way. Capacity is the part that resembles PCI — you can measure it, and you know when you are adding a tank. The discharge-history criteria are the part that does not. They are evaluated over the three years before the date you next sign, they can be satisfied by two comparatively small releases in a twelve-month period, and nothing marks the moment the answer changes. A facility can therefore be qualified in March and not qualified in June because of something that happened nineteen months earlier and was closed out at the time as a minor spill. This page is about tracking those dates and that status; it is not an SPCC-writing service, an environmental consultancy, or a source of engineering advice.
Whether a facility could reasonably be expected to discharge into navigable waters is the question that decides coverage, and the rule is unusually strict about how it must be answered. The determination has to be based solely on geographical and location factors — proximity to water, land contour, drainage — and it must expressly exclude consideration of manmade features such as dikes, equipment or other structures that may serve to restrain, hinder or contain a discharge. In other words, the secondary containment the plan would require you to build is legally invisible when working out whether you need the plan. Operators who reason that their bunded tank farm could never reach the creek are applying exactly the test the rule tells them not to apply.
2. How often must an SPCC plan be reviewed?
Review and evaluate the plan at least once every five years, counted from the date the facility became subject to the rule. You must document that you completed it and sign a statement recording whether the plan will be amended as a result — including when it will not.
Not only whether the plan still matches the site. The rule asks you to amend the plan within six months of the review to include more effective prevention and control technology, where that technology is field-proven at the time of the review and would significantly reduce the likelihood of a discharge.
A change in facility design, construction, operation or maintenance that materially affects discharge potential requires an amendment prepared within six months — and implemented as soon as possible, and no later than six months after it is prepared.
A qualified facility — Tier I or Tier II — may self-certify. Everyone else needs a plan certified by a licensed Professional Engineer for it to be effective. Technical amendments have to be certified the same way the plan was.
Exceed 10,000 gallons of aggregate aboveground capacity through a facility change and you have six months to move to a PE-certified plan. Separately, the discharge-history criteria look back over the three years before your self-certification date.
The first row is the one people quote, and the second is the one that changes what the review actually is. It is easy to read a five-year review as an accuracy check — walk the site, confirm the plan still describes it, sign it off. That is part of it. But the rule also asks whether prevention and control technology has moved on since the last time you looked, and requires an amendment where something now field-proven would significantly reduce the likelihood of a discharge. Read carefully, that makes the SPCC review partly a review of the outside world rather than of your facility. A plan can be entirely accurate, describing a site that has not changed in five years, and still require amendment because the state of the art moved while it sat in the binder.
The third row is where most of the missed deadlines actually live, and the wording repays attention. A qualifying change gives you six months to prepare an amendment. Preparing it then gives you no more than six months to implement it. These are not one deadline described twice; they are consecutive, and the second one does not exist until the first is met. That is an awkward shape for a calendar, because the date you would need to enter is not knowable when the change happens — it is set later, by your own act of finishing the amendment. Most obligations on this site end when you perform them. This one manufactures its successor.
The five-year review is not complete when the walk-around is done. The rule requires you to document completion and to sign a statement, kept at the beginning or end of the plan or in a log or appendix, recording whether you will amend the plan as a result — and it even supplies the wording. The practical consequence is that a facility which genuinely reviewed its plan on time, found nothing to change, and never wrote that down has a compliance gap that is indistinguishable, from the outside, from never having reviewed it at all. A review with no artifact is not evidence of anything.
It is worth being careful about names here, because this document goes by several and they are not interchangeable. The rule calls it a Spill Prevention, Control, and Countermeasure plan. Most sites call it the SPCC, or simply the spill prevention plan. A consultant's proposal will often offer an SPCC plan update, and a facility past the qualifying criteria will be quoted separately for an SPCC PE certification. The loose usage is harmless in conversation and expensive on a calendar, because those last two describe different acts with different obligations attached. An update is whatever scope was agreed with the supplier. The rule asks for something narrower and more specific: a documented five-year review with a signed statement recording the decision, or an amendment prepared and then implemented against two consecutive deadlines — and, at a facility that is not qualified, a technical amendment certified by the engineer in the same way the plan was. A site that commissioned an update, received a tidy revised document, and filed it has not necessarily satisfied any of those. Recording which act was performed, on what date, is the difference between a plan that looks maintained and one that can be shown to be.
One more detail from the first row is worth pulling out, because it decides where the five years are measured from. The clock runs from the date the facility became subject to the rule — not from the date the plan was written, not from the date it was certified, and not from a convenient calendar year. For a facility built as a bulk plant, those dates are close enough together that nobody notices the distinction. For a site that drifted into scope by adding storage over time, the date it became subject may be a delivery of drums on an ordinary afternoon, recorded nowhere except a purchase ledger. That facility owes a review five years from a day it would have to reconstruct.
There is a narrow extension route, and it is narrower than it first appears. The Regional Administrator may authorize extra time for preparing or fully implementing a plan or an amendment, but only on specific grounds: that qualified personnel were unavailable, or that construction or equipment delivery was delayed beyond your control and without your fault. Requesting one does not suspend anything — the rule states that submitting a request does not relieve you of the obligation to comply. It is a relief valve for the situation where the engineer or the equipment genuinely could not be had in time, not a way to buy room on an SPCC plan review that was simply forgotten.
3. Why tracking SPCC dates matters
A five-year interval sounds like the easiest thing on a compliance calendar to hold. In practice it is one of the hardest, and four properties explain why:
The interval is longer than the staff
Five years outlasts most people in a role. The person who signs the next review is usually not the person who signed the last one, and often has no idea one is owed.
A change opens two deadlines, in sequence
Six months to prepare the amendment, then six more to implement it. The second date cannot be entered in advance, because finishing the first is what creates it.
Who may sign it moves in both directions
Capacity and discharge history decide it, both can change, and the look-back is measured from whenever you next certify — so eligibility is lost and regained silently.
The count is the shell, not the contents
Capacity means the container's shell capacity. A tank that stood empty all year counts in full, and a facility with no tank at all can be covered by drums.
Start with the fourth, because it decides whether any of the others apply to you. The threshold is aggregate aboveground capacity of more than 1,320 US gallons, and the rule defines storage capacity as the shell capacity of the container. Not the contents. Not the average holding. Not the most you had at any point. A 2,000-gallon tank that has been drained since spring is 2,000 gallons for this purpose, and the only way a container leaves the total is to be permanently closed — which the rule defines as an actual procedure: liquid and sludge removed, lines disconnected and blanked, valves closed and locked, and a conspicuous sign posted on the container recording the date of closure. Emptying a tank does not reduce your aggregate. Retiring it properly, and documenting that you did, is what reduces it.
The counting rule beneath that is what quietly pulls sites into scope. Only containers of 55 gallons or more are counted — but they are all counted, and 55 gallons is a drum. Twenty-four drums of hydraulic oil on a rack is 1,320 gallons. Add a waste-oil tote and a generator day tank and a site with no tank farm, no fuel island and nobody who thinks of themselves as being in the oil business is over the line. The definition of oil is broader than most operators assume as well: it covers fats, oils and greases of animal or fish origin and vegetable oils from seeds, nuts, fruits or kernels alongside petroleum, fuel oil, synthetic and mineral oils. A food plant with bulk cooking oil is storing oil in exactly the sense the rule means.
This is a different problem from the one on EPCRA Tier II reporting, which many of the same facilities also owe, and the difference is worth being precise about because the two are easy to blur. Tier II asks what you actually had on site — the largest quantity present at any one time during a year that has already ended. It is a question about contents, answered backwards, and by the time it is asked the answer is fixed. SPCC asks what you are able to hold. It is a question about vessels, answered from a site walk and a tape measure, and it stays true whether or not a drop of oil ever went in. One is a fact about a year; the other is a fact about your yard.
Property 3.1 is unglamorous and does most of the damage. Compliance calendars are built by the people carrying this year's obligations, and a five-year interval is long enough that the plan, the review date, and the reasoning behind the certification route all leave the building with the person who set them up. What survives is the binder. A binder does not say when it was last reviewed against the rule, whether the signed statement was ever added, or why the site concluded it could self-certify. The successor inherits a document that looks complete and a deadline that looks like it must already be handled.
Property 3.2 breaks the ordinary shape of a reminder. Nearly every other date on this site is an endpoint: perform the test, file the return, renew the permit, and the cycle closes. An SPCC amendment is a relay. The change starts a six-month leg; completing that leg starts another six-month leg to implement what you prepared. A facility that commissions a new tank in January and prepares the amendment in June has not finished in June — it has just set a December deadline that did not exist in January and appears on no schedule anyone made. The commonest failure is not missing the first leg. It is treating the prepared amendment as the finish line.
The discharge-history criteria for self-certification are not written as a penalty with a start date. They are a look-back: over the three years before your self-certification date, was there any single discharge over 1,000 gallons, or two discharges each over 42 gallons within any twelve-month period, leaving aside those caused by natural disasters, acts of war or terrorism? Two releases a little larger than a drum, thirteen months apart, are enough. Nobody sends a letter when that becomes true, because it does not become true on a date — it becomes true whenever you next need to sign, and the answer depends on when that is. Which means the same facility, unchanged, can be ineligible to self-certify this quarter and eligible again a few months later, simply because the older discharge has aged out of the three-year look-back. It is the only obligation on this site where waiting is a legitimate way of restoring a status, and where nothing tells you it has been restored.
Property 3.3 is what makes that more than a curiosity, because the consequence of getting it wrong is not a late filing. It is a signature that should not have been given. A facility that self-certifies while outside the qualifying criteria has not merely missed a deadline — it has certified, among other things, that the facility meets the qualification criteria, which on those facts is not true, and it holds a plan that lacks the certification the rule requires to make it effective. That is a materially worse position than an overdue review, and it is reached by doing the paperwork rather than by neglecting it. Tracking what happened at the site, and when, is what lets the question be answered honestly before the pen moves.
The capacity side of the same property is more mechanical but no less easy to miss. If a facility change takes a Tier II qualified facility past 10,000 gallons of aggregate aboveground capacity, it has six months to prepare and implement a plan certified by a Professional Engineer. For a Tier I facility, exceeding the 5,000-gallon single-container limit or the 10,000-gallon aggregate produces the same requirement, counted from the preparation of the amendment. So the decision to add a tank is simultaneously an engineering decision, a purchasing decision, and a decision to book an engineer — and the third one is invisible to whoever makes the first two.
4. Who needs to track SPCC dates
Sites whose whole business is oil generally know the rule exists. The interesting list is the facilities that store oil incidentally, and the people whose job the plan quietly became:
Fuel distributors & bulk plants
Well past any qualifying threshold, so the plan is PE-certified and every technical amendment needs the engineer back. The review date and the engineer's availability are the same planning problem.
Learn More
Manufacturers & food plants
Hydraulic and lubricating oil around the plant, and — because the definition of oil includes animal fats and vegetable oils — bulk cooking oil too. A processor can be an oil storage facility with no fuel on site.
Sites that got there by accumulation
No tank farm and no fuel island — just drums on a rack, a waste-oil tote and a day tank, adding up past 1,320 gallons. Nothing announced the crossing, so nothing started the five-year clock in anybody's diary.
Learn More
Farms & agricultural operations
On-farm bulk fuel, lubricants and equipment oil, on a definition of farm that reaches any tract producing a thousand dollars of agricultural products — and a review date five years out from a season nobody diarized.
Marinas & waterfront operations
Where the location test is never in doubt and the transfer operations change with the season — so amendments are triggered more often than the five-year review ever comes round.
EHS & facilities managers
Carrying several sites with different tiers, different certifiers and different review dates — where one site being current says nothing at all about the one down the road.
Learn MoreThe third card is the one that produces the most surprised phone calls, and it is worth separating from the neighboring obligation it is most often confused with. A regulated buried fuel tank has its own body of rules, its own testing intervals and its own registration, all covered on underground storage tank compliance — and the SPCC rule itself steps out of the way there, excluding completely buried tanks that are subject to the underground storage tank requirements from the buried capacity it counts. So the two obligations never double up on the same tank; they attach to different assets. A site can easily owe both, for different equipment, on unrelated calendars, and be perfectly current on one while not knowing the other exists.
The last card describes the practical reality for anyone holding more than one location, and it is where a per-site record stops being administrative tidiness. SPCC status is decided facility by facility. Two sites owned by the same company, with the same operations, can sit on different sides of the qualifying line because one added a tank, or because one had a pair of small releases inside a twelve-month period and the other did not. Their review dates differ because they became subject to the rule on different days. And the certification route differs, which means the lead time differs, because booking an engineer is not the same task as scheduling your own site walk. For everything a site like that carries alongside the plan — permits, inspections, training records — health and safety tracking holds them in the same register: tracking and reminders, not an EHS management system.
5. What happens when an SPCC obligation slips
SPCC failures come in four distinct shapes. They are enforceable separately, they are discovered in different ways, and only one of them looks like a missed deadline.
No plan at all, at a facility the rule covers. This is the most common and the least intentional. It is produced by the combination described in section 3: a capacity test measured in shell gallons, a 55-gallon counting floor that sweeps in drums, a definition of oil that includes vegetable oils and animal fats, and a location test that forbids you from taking your own containment into account. A facility can satisfy every one of those conditions while sincerely believing it stores no oil in any regulated sense. There is no registration step to reveal the mistake and no correspondence to prompt a second look, so the discovery usually happens when an inspector arrives, or after a release, when the first question asked is for the plan.
A plan that exists but has not been reviewed. This is the conventional failure and the easiest to prevent. A plan sitting in the binder for six years is out of compliance whether or not the facility changed, because the review obligation is independent of whether there was anything to find. The variant that catches conscientious sites is subtler: the review was done, on time, by someone who walked the yard properly and concluded that nothing needed changing — and then did not document completion or sign the statement the rule requires. From the outside those two facilities are identical. Both have a plan with nothing recorded against it for six years.
A change that was never reflected in the plan. The rule's own list of examples is broad enough to be worth reading against your own site: commissioning or decommissioning containers, replacing, rebuilding or moving them, reconstructing or installing piping, construction or demolition that might alter secondary containment, a change of product or service, and revisions to standard operating or maintenance procedures. Several of those are things a maintenance department does as ordinary work, without a project, a budget line or a moment at which anyone thinks about the plan. The plan then describes a site that no longer exists — and since it is also the document that is supposed to tell responders where the oil and the containment are, the inaccuracy is not only a paperwork problem. Then there is the second leg: amendments prepared and never implemented, which is a failure with a document to show for it and is therefore particularly easy to believe you have handled.
A plan signed by the wrong party. This is the failure with no equivalent elsewhere on this site, and it is reached by being diligent rather than by being late. A facility self-certifies its plan, on time, having genuinely reviewed it — but the qualifying criteria were not met, because aggregate capacity crept past the line when a tank was added, or because the discharge history in the three years before signing included two releases each a little over 42 gallons within twelve months. The certification includes an express statement that the facility meets the qualification criteria, so the defect is not a technicality about who held the pen. And because the rule requires the appropriate certification for a plan to be effective, what the facility holds is not an imperfectly certified plan but, in the terms of the rule, not an effective one.
EPA can inspect a covered facility at any time and can require the plan to be available for on-site review during normal working hours — and a complete copy has to be kept at the facility itself if it is attended at least four hours a day, or at the nearest field office if not. That last requirement quietly rules out the arrangement many multi-site operators drift into, where the only current copy of every plan lives with the consultant who wrote them. Discharges also bring their own consequences under the Clean Water Act quite apart from the state of the plan, and a release at a facility that turns out to have no plan, a lapsed review, or a certification it was not entitled to give is a materially different conversation from the same release at a facility whose paperwork is in order.
None of these four failures announces itself. That is the through-line. There is no renewal notice, no portal that goes red, no counterparty asking for a current certificate. The whole system assumes the facility is keeping track of its own dates, which is a reasonable assumption about a bulk terminal with an environmental manager and an unreasonable one about a fabrication shop that crossed 1,320 gallons three years ago by buying drums.
6. How Remindax keeps your plan current and correctly certified
Remindax holds the dates and reminds the people who have to act on them. It does not write, review, certify or amend plans, and it is not an engineering, EHS or environmental consulting service.
Every SPCC date in one dashboard
The five-year review date, the certification record, and any amendment deadlines currently running — held per facility, with status at a glance. Pairs with Locations asset profiles, so a plan lives where the containers physically sit.
Reminders with real runway
Staged alerts by Email, SMS and WhatsApp, set far enough ahead that an engineer can be booked rather than chased — and addressed to a named person, which matters when self-certification requires that person's own site visit.
The second deadline, once the first is met
Record when an amendment was prepared and set the implementation date it creates — the leg that most often goes missing, because it does not exist until the amendment is finished.
Every site tracked separately
Different tiers, different certifiers, different review dates. One facility being current is never mistaken for the group being current, and each site's reminders reach its own people.
A record an inspector can follow
When each review was completed, when each amendment was prepared and implemented, and when the plan was last certified — organized per facility, so the history exists independently of whoever was in the role at the time.
Dates and status only
GDPR-ready, hosted on AWS secure cloud with encrypted storage. Remindax holds when things are due and whether they were done — not your plan's contents, your site drawings, or discharge details.
The one thing worth saying about how a reminder is aimed: on most obligations it is enough that the alert reaches the team. Here it often is not. A PE-certified plan needs an engineer engaged early enough to visit, and a self-certified one needs the owner or operator personally on the site — not a delegate, not a contractor. A reminder that reaches a shared mailbox six weeks out satisfies neither. Setting the recipient and the lead time deliberately, per facility, is most of the value.
7. Why spreadsheets fail for SPCC tracking
A spreadsheet is a reasonable tool for a list of dates that are known in advance and arrive on schedule. Almost nothing about SPCC fits that description.
It has no way to hold a deadline that does not exist yet. The implementation date created by preparing an amendment cannot be typed in when the change happens, because it is set by a future act — so the row either sits empty or gets filled with a guess, and in both cases nothing pushes it at anyone. It has no way to notice that a facility change has occurred at all: commissioning a container, moving one, reworking piping or revising a maintenance procedure are things that happen in a maintenance system, not in a compliance file, and no formula connects the two. It cannot tell you that a run of small releases has quietly moved a site out of the qualifying criteria, or that time has moved it back in, because that answer depends on a look-back measured from a date you have not chosen yet.
And it will not survive the interval. A five-year review outlasts the spreadsheet's author, the file's location, and usually the version of the file anyone is still opening. The specific thing that gets lost is not the date — it is the reasoning: why this site self-certifies, what its aggregate capacity was when that was decided, and which day it became subject to the rule in the first place. Without that, the next review starts by reconstructing a judgment rather than by performing one.
A system that holds the five-year review, the amendment deadlines and the certification record per facility, reminds a named person with enough runway to book an engineer, and keeps the record of what was done and when, is what turns SPCC from something a site remembers into something a site can show. The plan stays current, correctly certified, and available at the facility when someone asks for it.
8. Key takeaways
- ✓The SPCC rule requires facilities storing oil above the capacity thresholds, that could reasonably discharge to navigable waters, to prepare and implement a written plan — and the location test excludes the containment you have built.
- ✓Capacity means shell capacity, only containers of 55 gallons and up are counted, and oil includes vegetable oils and animal fats — so an empty tank counts in full and a site with no fuel can still be covered.
- ✓The SPCC 5-year review runs from the date the facility became subject to the rule, and completing it requires a documented, signed statement — even when nothing is being changed.
- ✓A qualifying facility change gives six months to prepare an amendment and no more than six further months to implement it — two deadlines in sequence, the second created by meeting the first.
- ✓Tier I and Tier II qualified facilities may self-certify; everyone else needs a licensed Professional Engineer, and without the required certification the plan is not effective.
- ✓Eligibility to self-certify moves in both directions — capacity can end it within six months, and the three-year discharge look-back is measured from whenever you next sign, so it can lapse and return with nothing announcing either.
- ✓Tracking the review date, the amendment deadlines and the certification record per facility is what keeps the plan current, correctly signed, and ready when an inspector asks for it on site.
Never let your spill plan go stale — or wrongly signed
Track every SPCC review, amendment and certification date — automatically, for every facility. Remindax holds the dates, keeps the record of what was done and when, and reminds the right person while there is still time to book an engineer.
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9. Frequently Asked Questions
At least once every five years. The SPCC 5-year review runs from the date your facility became subject to the rule, not from the date the plan was written, and you must document that you completed it and sign a statement saying whether the plan will be amended as a result - even when the answer is no. If the review identifies field-proven technology that would significantly reduce the likelihood of a discharge, you amend the plan within six months of the review and implement the amendment as soon as possible, and no later than six months after it is prepared.
Facilities that store oil and, because of where they are, could reasonably be expected to discharge it into navigable waters or adjoining shorelines. The capacity test is generally more than 1,320 US gallons of aggregate aboveground storage - counting only containers of 55 gallons or more - or more than 42,000 gallons completely buried. One point catches people out: the location test looks solely at geography and drainage and expressly excludes manmade features such as dikes and other structures that would restrain a discharge, so containment you have already built cannot be the reason the rule does not reach you.
It depends on the facility. A licensed Professional Engineer must review and certify the plan for it to be effective, except at a qualified facility, where the owner or operator may self-certify instead. Qualified facilities are those that meet the Tier I or Tier II criteria on aggregate aboveground capacity and recent discharge history. States and localities can add their own oil-storage requirements, so confirm what applies to your site with your state agency.
Tier I is a subset of Tier II, not a separate track. A Tier II qualified facility has 10,000 US gallons or less of aggregate aboveground oil storage capacity and meets the discharge-history criteria. A Tier I facility meets all of that and additionally has no individual aboveground container larger than 5,000 gallons - which lets it use EPA's Appendix G template as its plan. Both may self-certify.
Yes, and there are two separate ways. A capacity change can end it: if a facility change takes you past 10,000 gallons of aggregate aboveground capacity, you have six months to move to a plan certified by a Professional Engineer. Discharge history can also end it - the criteria look back over the three years before the self-certification date and ask whether there was any single discharge over 1,000 gallons, or two discharges each over 42 gallons within any twelve-month period, excluding discharges caused by natural disasters, acts of war or terrorism. Because that window is measured backwards from whenever you next certify, the same facility can be qualified at one moment and not at another without anything physical changing.
A change in facility design, construction, operation or maintenance that materially affects the potential for a discharge. The rule's own examples include commissioning or decommissioning containers, replacing, rebuilding or moving containers, reconstructing or installing piping, construction or demolition that might alter secondary containment, a change of product or service, and revisions to standard operating or maintenance procedures. An amendment must be prepared within six months of the change and implemented as soon as possible, and in any event no later than six months after it is prepared.
Yes. Storage capacity means the shell capacity of the container, so a 3,000-gallon tank counts as 3,000 gallons whether it is full, part full, or has stood empty all year. The only way a container leaves the count is to be permanently closed, which is a defined procedure rather than a decision - liquid and sludge removed, lines disconnected and blanked, valves closed and locked, and a conspicuous sign posted on the container noting the date of closure.
Yes. Oil is defined broadly and includes fats, oils and greases of animal or fish origin and vegetable oils from seeds, nuts, fruits or kernels, as well as petroleum, fuel oil, synthetic and mineral oils. A food plant holding bulk cooking oil can therefore be an oil storage facility for these purposes even though nothing on site is a fuel.
No. Remindax tracks the dates - the 5-year review, the amendment windows a facility change opens, and the certification or re-certification date - and reminds the people responsible. Writing the plan, conducting the site visit and examination, certifying it, and amending it are done by you and your engineer. Remindax is not an SPCC-authoring, environmental-consulting, EHS or engineering service and does not provide Professional Engineer certification.
Yes. Each site carries its own 5-year review date, its own amendment prompts, and its own certification record, with its own reminders and its own recipients. That matters because SPCC status is decided facility by facility - one site can be a Tier I qualified facility while another a few miles away needs a Professional Engineer, and neither one's standing says anything about the other's.
Yes - a forever-free plan, no credit card required.
SPCC requirements are set by EPA under 40 CFR Part 112, and states and localities can add their own oil-storage rules. Remindax tracks the dates and reminds you; it doesn't write, review, certify or amend plans, inspect facilities, or provide engineering, EHS or environmental consulting services. Confirm what applies to your facility at the official sources below; this is general information, not environmental, engineering or legal advice.
11. Sources & references
This page summarizes public requirements and isn't environmental, engineering, EHS or legal advice. States and localities can impose additional or stricter oil-storage requirements — confirm what applies to your facility at the official sources below and with your state agency.
- •EPA — Oil Spills Prevention and Preparedness Regulations — EPA's overview of the SPCC rule: who it applies to, what a plan must contain, and how the program is administered.
- •EPA — Is My Facility a “Qualified Facility” under the SPCC Rule? — the Tier I and Tier II criteria for self-certification, including the aggregate capacity limits and the discharge-history test.
- •EPA — Visit and examination requirements for SPCC self-certification — confirms that a self-certifying owner or operator must personally conduct the site visit and examination, with no provision for an agent or employee.
- •40 CFR § 112.1 — General applicability — the 1,320-gallon aboveground and 42,000-gallon buried thresholds, the 55-gallon counting floor, and the rule that the location test excludes manmade features.
- •40 CFR § 112.3 — Requirement to prepare and implement an SPCC Plan — the Professional Engineer certification and what it attests, the extension-of-time provision, and the Tier I and Tier II qualified facility criteria.
- •40 CFR § 112.5 — Amendment of an SPCC Plan by owners or operators — the five-year review and evaluation, the signed statement it requires, and the six-month deadlines to prepare and implement an amendment.