The EPA extended the deadline date from Nov. 10, ’11 to May 10, ’13 by which owners or operators of a farm must prepare or amend and implement an Oil Spill Prevention, Control, and Countermeasure Program Plan (SPCC). However, owners and operators of regulated facilities should pay close attention to guidelines to ensure that their SPCC Plan is in place in a timely fashion. Many farms and all gins should already have a plan in place.

Farms in operation on or before Aug. 16, '02, must maintain (have a plan in place now) and amend their existing plan if needed by May 10, '13. Farms in operation after Aug. 16, '02, but before May 10, '13 must prepare and implement a plan on or before May 10, '13. Farms that begin operations after May 10, '13 will be required to have a plan in place before they begin.

Gins were excluded from this compliance date extension. Currently, gins in operation on or before Aug. 16, '02, must have a plan in place. Gins in operation after Aug. 16, '02, but before Nov. 10, '11 also are required to have a plan in place at this time. Gins that start operations after Nov. 10, '11 must have a plan in place before they begin.

The EPA’s SPCC Farms Fact Sheet at www.epa.gov/emergencies/docs/oil/spcc/spccfarms.pdf is perhaps the best information source for evaluating responsibilities under the SPCC Program. Farm and gin owners/operators should first establish whether they qualify as a regulated facility. Owners/operators are reminded that containers on separate facilities are not to be added together when determining total oil storage capacity. It is not uncommon for a farm to be comprised of multiple facilities with respect to oil storage. It is also recommended that owners and operators document and file explanations of circumstances that exclude them from this rule. Exemption from this rule does not exclude responsibilities for clean-up of oil spills or any containment requirements for their storage containers.

NCC also updated its slide set at www.cotton.org/tech/safety/upload/SPCCUpdate.pdf that may be useful in helping explain the basics of the SPCC Program. The slides include information regarding who is covered, what a covered facility should do, current deadlines and where to get additional information.

Owners or operators of qualified facilities should not wait until May 10, ’13 to prepare or modify their existing plan. They also are urged to contact a qualified Professional Engineer as soon as possible if self-certification is not an option.