Spill kits are a critical component of any facility’s spill prevention and response program. While no single OSHA or EPA regulation specifically mandates spill kits by name, multiple regulatory frameworks effectively require them. OSHA’s HAZWOPER standard (29 CFR 1910.120) requires sufficient absorbent and containment supplies for emergency response. The EPA’s SPCC rule (40 CFR 112) requires appropriate containment equipment for facilities storing oil. OSHA’s walking and working surface standard (29 CFR 1910.22) requires work surfaces to be kept clean and dry. A spill kit that is empty, improperly stocked, inaccessible, or contains degraded materials is as ineffective as having no kit at all. This guide covers all inspection requirements with a free downloadable checklist.
Free Spill Kit Inspection Checklist
Download our Word document checklist covering absorbent inventory, PPE condition, containment equipment, and signage per OSHA and EPA requirements.
Download Checklist (.docx)Regulatory Framework
OSHA Requirements
- General Duty Clause (Section 5(a)(1)): Employers must provide a workplace free from recognized hazards. Facilities handling hazardous or flammable liquids must have appropriate spill response capabilities.
- 1910.120 (HAZWOPER): Requires employers to have “sufficient quantities” of absorbents and salvage drums for emergency spill response. Spill response personnel must be trained to the appropriate HAZWOPER level.
- 1910.22 (Walking-Working Surfaces): All floors and walking surfaces must be kept clean, dry, and free from hazards. Spills must be cleaned up promptly.
- 1910.106 (Flammable Liquids): Storage areas for flammable liquids must have adequate drainage and spill containment provisions.
EPA Requirements
- 40 CFR 112 (SPCC Rule): Facilities storing over 1,320 gallons of oil aboveground or 42,000 gallons buried must develop an SPCC plan with appropriate containment and diversionary equipment, including spill kits as a best management practice.
- 40 CFR 264/265 (RCRA): Hazardous waste treatment, storage, and disposal facilities must maintain spill control equipment and adequate aisle space for emergency response.
- Stormwater Pollution Prevention Plans (SWPPP): Spill kits can be written into SWPPPs as a best management practice to prevent discharge of pollutants to stormwater.
Restock immediately after any use: Any spill kit that has been partially or fully used must be inspected and restocked immediately. Document all spill kit usage, including the date, type of spill, quantity of materials used, and restocking actions taken. Depending on spill size and substance, the event may be reportable to OSHA and/or EPA.
Part 1: Absorbent Materials & Supplies
| Inspection Item | What to Check |
|---|---|
| Absorbent pads | Adequate quantity of absorbent pads present (per kit contents list). Pads clean, dry, and not previously used. Correct type for the hazards in the area: oil-only (white, hydrophobic) for petroleum products, universal (gray) for oils and water-based fluids, or hazmat (yellow) for aggressive chemicals. Pads not deteriorated, discolored, or water-damaged. |
| Absorbent socks and booms | Absorbent socks/booms present in specified quantity. Socks not saturated, hardened, or previously used. Length adequate for containment needs. Fill material evenly distributed (no lumps or bare spots). Correct type (oil-only, universal, or hazmat) matched to area hazards. |
| Loose absorbent | Granular or loose absorbent (if included) present in adequate quantity. Material dry and free-flowing. Container or bag intact and sealed. Correct type for the substances stored in the area. Scoop or spreader available for application. |
| Disposal bags | Heavy-duty disposal bags present in adequate quantity. Bags large enough for used absorbent materials. Bags not torn, punctured, or degraded. Zip ties, twist ties, or closure devices available. Bags meet waste disposal requirements (color-coded for hazardous waste if applicable). |
| Overpack drum (if included) | Overpack drum present and in good condition. Drum lid removable and functional with secure closure. Capacity appropriate for the largest container in the area. No cracks, dents, or damage. UN/DOT rated if required for hazardous material transport. Drum bung wrench available. |
Part 2: Personal Protective Equipment
| Inspection Item | What to Check |
|---|---|
| Gloves | Chemical-resistant gloves present (nitrile, neoprene, or butyl as appropriate for area hazards). Multiple pairs available. Gloves in original packaging or stored clean. No tears, holes, or degradation. Size range adequate. Glove type compatible with chemicals stored in the area per SDS recommendations. |
| Eye and face protection | Safety goggles or splash-proof chemical safety glasses present. Goggles clean, unscratched, and with functional seal/strap. Face shield available where splash hazard warrants (corrosive or highly toxic materials). Lenses not discolored or degraded. |
| Protective clothing | Chemical splash apron or disposable coveralls present (where required for area hazards). Garments in original packaging or stored clean. No tears, holes, or chemical damage. Appropriate chemical resistance for substances in the area. Boot covers or shoe covers available if needed. |
| Respiratory protection | Dust mask or respirator present if required for the substances in the area. Correct cartridge type for area hazards (organic vapor, acid gas, etc.). Cartridges within shelf life and properly sealed. Respirator clean and stored in protective case. Users must be fit-tested and medically cleared per 1910.134. |
Part 3: Kit Condition, Location & Documentation
| Inspection Item | What to Check |
|---|---|
| Kit container condition | Spill kit container (bin, bag, drum, or cabinet) in good condition. Container lid or closure functional and weather-resistant (for outdoor kits). No water intrusion, pest contamination, or UV degradation. Contents list/inventory card posted on or inside kit. Container clearly labeled “SPILL KIT” with contents description. |
| Accessibility | Kit location easily accessible without moving equipment or materials. Kit positioned near the most likely spill source area. No obstructions blocking access (pallets, equipment, vehicles). Kit within reasonable response distance (generally within 200 feet of hazard area). Accessible from multiple directions where practical. |
| Signage and identification | Spill kit location clearly marked with signage visible from work areas. Sign identifies kit type (oil, chemical, universal). Emergency contact numbers posted on or near the kit. Spill response procedures posted or laminated instruction card in kit. Kit location shown on facility emergency response maps/plans. |
| Contents inventory | Kit contents match the posted inventory/contents list. All items present in specified quantities. No items missing, partially used, or substituted. Inventory list includes minimum restock quantities. Contents appropriate for the specific hazards in the kit’s assigned area. |
| Training documentation | Employees in the kit area trained in spill response procedures. Training includes kit location, contents, proper use, personal protection, and notification requirements. Training records current (initial plus annual refresher per HAZWOPER). Employees know reportable spill thresholds for OSHA and EPA notification. |
| Drain protection | Drain covers or plugs present where floor drains exist in the spill response area. Covers sized to fit facility drains. Covers clean and unobstructed for quick deployment. Storm drain locations identified and marked near outdoor spill kit stations. Absorbent booms available for drain perimeter protection. |
Spill kit types and applications: Oil-only kits (white absorbents): absorb petroleum products while repelling water — ideal for outdoor and marine use. Universal/general-purpose kits (gray absorbents): absorb oils, water-based fluids, coolants, and solvents — suitable for most industrial settings. Hazmat/chemical kits (yellow absorbents): absorb aggressive chemicals including acids, bases, and unknown substances — required where corrosive or toxic materials are stored. Match kit type to the specific substances stored or used in each area based on Safety Data Sheet (SDS) information.
Download the Free Checklist
Get our spill kit inspection checklist in Word format. Covers absorbent inventory, PPE, kit condition, and documentation requirements.
Download Checklist (.docx)Go digital with Ecesis. Manage spill kit inspections across your facility with Ecesis inspection software. Track kit locations, contents inventory, and restocking needs. Document inspections with timestamped photos. Automate corrective actions when kits need restocking. Integrate with your SPCC plan and stormwater BMP program. Request a free demo.
Ecesis EHS Software
Inspections
Monthly spill kit inspection checklists with contents verification and photo documentation.
Chemical Management
Match spill kit types to stored chemicals using SDS data and chemical inventory records.
Compliance Calendar
Schedule monthly inspections, annual SPCC plan reviews, and HAZWOPER training renewals.
Task Management
Assign restocking actions, PPE replacement, and spill response procedure updates.
Incident Management
Report spill events, track cleanup actions, and manage regulatory notifications.
Training
Track HAZWOPER training, spill response drills, and SPCC employee awareness training.
