If your company stores oil-based inks and manages them as part of your facility’s Spill Prevention, Control and Countermeasures (SPCC) Plan, it may be feasible to use an impracticability determination as an alternative approach to comply.
Read the article by Chris Jimieson of SCS Engineers.
The high viscosity of oil-based inks can provide an opportunity for an alternative means of complying with the secondary containment requirements of the SPCC Rule. An impracticability determination can be an appropriate option for oil-based ink you store in single walled containers at print or similar facilities.
