EPA to Regulate Milk Storage |
| Posted by Robert Sherby on Jun 02 2010 |
In March 2010, the US EPA updated its information for farmers concerning their need to have on-hand a Spill Prevention, Control, and Countermeasures Plan (SPCC Plan) on any farm which stores more than 1,320 gallons of oil products in aboveground storage tanks or 42,000 gallons in underground storage tanks. The most notable feature of the EPA's guideline is that it includes "animal fat" as a regulated oil product. By including animal fat, the EPA has brought milk under its regulatory wing.
Although SPCC requirements are new to many dairy farmers, they are the same requirements that the petroleum industry has been familiar with for years. In fact, some large scale farmers who already store a significant amount of fuel are likely to have an SPCC Plan already.
For smaller farmers, however, much of the SPCC regulation is likely to be unfamiliar and confusing. According to some math done by Paul Jackson in the Michigan Farm News, the SPCC regulation may affect farms with fewer than 150 cows. The smallest farms, those with fewer than 10,000 gallons of total storage and no storage tank greater than 5,000 gallons in size, will be able to self-certify using a template provided by the EPA. Farms with under 10,000 gallons of total storage but with at least one tank over 5,000 gallons in size will be allowed to self-certify, however, the EPA offers no template for compliance. Farms with over 10,000 gallons of total storage, farms which have experienced a spill, and farms of any size which use "alternate methods" of spill prevention and control must have a plan signed by a Professional Engineer.
Farmers will also, of course, be required to implement or verify the spill controls described in their SPCC Plans. There is no way to know at this point how many farms have compliant controls, but based on our experience in the petroleum industry, we would encourage most affected farmers to plan on some maintenance costs between now and November.
Last changed: Jun 02 2010 at 7:42 AM
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