OSHA and EPA Compliance for Secondary Containment

The importance of active and passive systems for secondary containment were explained in Unit 3. These systems serve as a backup containment in the instance of a hazardous waste spill. There are many ways to prevent a leak, spill, or discharge in the first place. Being able to respond in the event of a failure is integral for the safety and well-being of workers, the environment, and the surrounding population. OSHA and the EPA have multiple guidelines regarding secondary containment systems, providing options for the best method of compliance for site-specific adherence. However, the EPA gives more structure to these guidelines.

The EPA says that a secondary containment system for tanks must meet the following criteria:

• Be designed and installed in such a way as to prevent a migration of the hazardous material toward soil or a body of water.
• Be capable of collecting any hazardous material released until it can be removed.
• Be constructed of a material, or lined with a material, both appropriate for, and strong enough to withstand the hazardous material.
• Be placed on a foundation or base that will not settle or shift.
• Have a leak detection system.
• Be sloped or designed to drain or remove liquids.

A secondary system for portable containers, such as drums, must meet the following criteria:

• Be placed on a foundation that is free of cracks or gaps and is able to contain any leaks or spills until the hazardous material can be properly removed.
• Be on a base that is sloped unless the containers are protected from coming in contact with any potential liquids that could accumulate.
• Be able to contain ten percent of the volume of the containers or hold the amount equal to the volume of the largest container, whichever of these two is greater.
• Be able to prevent run-on from entering the containment system.
• Be cleaned of any spilled or leaked waste as timely as possible to prevent potential overflow issues.

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