What should the capacity of the spill containment berm be?

24.05.2022

What should the capacity of the spill containment berm be?

Pojemność wanny wychwytowej

What capacity should the sump tray have? Unfortunately, the answer to this question is “it depends”. The legal status in Poland regarding the safe storage of hazardous substances is still ambiguous in this respect. In the following article I will explain where this ambiguity comes from and what determines the capacity of the bathtub.

What determines the capacity of the spill containment berm?

First, we need to define what will be stored in the berm:

  • Flammable liquid waste: be sure to check the “Regulation of the Minister of Interior and Administration of February 19, 2020 on fire protection requirements to be met by construction structures or their parts and other places for collecting, storing or processing waste” – see more
  • Toxic or corrosive materials in tanks subject to the Office of Technical Inspection (UDT): be sure to check the “Regulation of the Minister of Economy of April 16, 2002 on the technical conditions of technical inspection to be met by pressureless and low-pressure tanks intended for the storage of poisonous or corrosive materials” – See more
  • Other hazardous substances (a pictogram on the packaging is enough) or posing a risk of accident after the container / installation becomes unsealed: the rules for creating safe workplaces and other regulations apply – see more

Types of substances and the required capacity of the berm

List of differences resulting from the substance stored in a specific berm:

The type of substanceLeading legal basisThe required capacity of the berm or drip tray
Liquid
waste
combustible
Regulation of the Minister of the Interior and Administration of February 19, 2020 (…)25% of the total volume of liquid combustible waste stored.

110% of the capacity of the single largest package, unit container or portable tank – whichever is greater.

Specific technical guidelines regarding the dimensions and construction of the sump.

Toxic and corrosive substances (UDT supervision)Regulation of the Minister of Economy of April 16, 2002 (…)Minimum 100% of the capacity of one tank: The leakage protection device should have a capacity not less than the capacity of the tank it protects.

75% of the capacity of two tanks, but not less than the capacity of a larger tank.

50% of the capacity of three or more tanks, but not less than the capacity of the largest tank.

Other hazardous substancesLabor Code

Regulations of the Minister of Labor and Social / Social Policy

The internal security rules of the Company

The employer is obliged to protect the health and life of employees by ensuring safe and hygienic working conditions with the appropriate use of the achievements of science and technology.

Good practice: not less than 25% of the total volume of substances stored in it or 110% of the capacity of the single largest container

source: own study

In the case of storing liquid flammable waste as well as poisonous and corrosive substances in tanks under the supervision of the Office of Technical Inspection, the requirements for the capacity of the sumps are clearly specified. The remainder, possibly the largest group of employers, must rely on general regulations and “industry rules” when using advisory bodies – occupational health and safety workers or experts.

My many years of discussions with experts in the field of security design in enterprises indicate that the following principle can be adopted as good practice in general:

The net capacity of the sump tray container should be not less than 25% of the total volume of the substances stored in it or 110% of the capacity of the single largest package, unit container or portable tank – whichever is greater.

However, it should be remembered that ultimately it is the Employer who defines safety and determines whether the indicated capacity of the sump may be greater due to e.g. the frequency of verification of the condition of the containers, experience with failure rate and the number of packaging damage events, increased degree of chemical risk or environmental impact. An example is the refining industry, where the minimum sump capacity is often 150% of the volume of the stored containers.

The most important principle of selecting a sump is to increase the level of safety for employees and reduce the risk of threats resulting from unsealing of containers. Guided by this principle, let us choose solutions that will provide us with all this with their quality and functionality.

Przemysław Domagalski

President of Exflo Sp. z o.o., a regular participant of trainings and workshops on the storage of hazardous substances, certified internal ISO 14001 auditor, co-creator of practical products supporting environmental protection.