Sometimes an SPCC plan is expensive to develop and update with every process change. Should every manufacturing facility have a SPCC plan? What are the pros and cons of establishing and maintaining such a plan? Suppose there was a moderately large gasoline spill in the evening shift and the spill was left, as is, overnight; the evening shift manager planned for the day shift supervisor to address the spill. By morning, the spill had gradually seeped into a nearby creek and impacted its water with petroleum hydrocarbons. As you know, small creeks flow into large streams and rivers. Some kind of cleanup has to be initiated quickly.

Whose fault is it? Is the supervisor on duty at fault? Is the manufacturing facility environmental & safety manager at fault for not having a SPCC plan? What kind of superficial drainage pattern or other controls would have helped prevent impact to the creek? Would a SPCC plan have prevented or minimized the environmental impact of this spill? What other actions are required by the facility as a result of this spill?