activities must anticipate possible interactions between the hazardous material, the people, and
the equipment involved in its handling from the time it is received until the time it is shipped.
Once these interactions are identified, measures can be developed and implemented to eliminate
or reduce the probability of spills or chemical releases.
7.7 The Human Factor
A. Supervisors are responsible for ensuring employee compliance with safety and health
standards. The supervisors, with environmental personnel, are responsible for identifying
hazards in the workplace and initiating action to eliminate such hazards, and must be considered
a principal participant in SPCC development.
B. Investigation reports frequently conclude that spills and releases of hazardous substances are
the result of human error or negligence. Because of the complexity of human behavior and
varying individual attitudes, the human factor is perhaps the most difficult to address. The role
of human error as a contributing factor in spills can be reduced to some extent by appealing to the
employee's instinct for survival. If they are aware that negligence in the workplace might cost
them their lives, they are more likely to exercise caution when handling hazardous materials. It
becomes the supervisor's responsibility to ensure employee awareness of the hazards associated
with the chemicals they handle. Employees must be adequately indoctrinated before entering the
work area where hazardous materials are handled and must receive periodic refresher briefings.
They must also clearly understand how their present duties and responsibilities relate to the
overall facility and national objectives of spill prevention programs.
C. Required internal controls must be in effect to reduce the probability of accidental spills and
releases in the warehouse. Such controls include limiting the speed of materials handling
equipment (MHE), restricting forklifts carrying hazardous materials to specific aisles, and using
personal protective clothing and equipment. Individual work habits must also be continuously
observed to ensure that they conform to accepted standards. Supervisors are encouraged to
consider spill prevention goals when developing employee written performance standards. This
should be done in consultation with the local personnel office.
7.8 Physical Security. Physical security is defined as those measures designed to safeguard
personnel; prevent unauthorized access to equipment, facilities, materials, and documents; and
safeguard them against sabotage, espionage, damage, and theft. Facility coordinators will ensure
that command security plans specifically include hazardous materials. SPCC security provisions
will provide for effective and efficient utilization of personnel and equipment and will be flexible
enough to permit timely changes to meet emergencies.
A. MHE, both mechanized and nonmechanized, must be considered a key factor in developing
SPCCs. Operators must be thoroughly trained in MHE operation. Movement of hazardous
materials within the warehouse should be kept to a minimum. Movement paths should be
continuously studied for the possibility of reducing "back-tracking" and length of moves.
Equipment capabilities should never be exceeded. Overloading causes excessive equipment