What is oil?
Posted on June 8, 2017
Many clients of ours often have questions about what is an oil and specifically what should be included as an oil in an SPCC Plan. The most common misconception that we hear is that an SPCC only deals with “petroleum-based oils” and everything else is exempt. The following excerpt taken directly from the SPCC Rule found in 40 CFR Part 112 clearly indicates that there are many other types of oil that also need to be included in an SPCC Plan.
§112.2
Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.
“Oil of any kind or in any form” generally casts a very wide net and includes anything you could possibly think of that is oily. When in doubt, it should probably be included in an SPCC Plan.
We have heard clients say they do not want to include various types of oil because the oil is “not petroleum based”, “natural”, or only “vegetable oil” and other similar type excuses. As you can read directly from the regulation above, it includes oils from nature, vegetable oils, nut oils, petroleum oils, as well as synthetic oils. Believe it or not, butter is considered an oil!
If you wish to verify specifically if a product is considered an oil, the United States Coast Guard maintains a 6-page list of products that are considered oil. Also, be careful because in the very top of this list, they state that “Some substances that have not been considered oils historically may be added to this list in the future if they are determined to have oil-like characteristics.”
https://www.uscg.mil/hq/cg5/cg5215/docs/2013.03.18_OPA90_Oils_and_oil-likes.pdf
Some of the non-petroleum oils that we encounter quite regularly are mineral spirits, mineral oil, turpentine, tall oil, silicone (used in many defoamers), and vegetable oils (used in transformers).
When in doubt, look it up and remember that if it is “oil-like” or creates a sheen on water, then it is probably better to include it in your plan.