I think most EHS professionals will agree that bulk tanks of hazardous materials need some means of “secondary containment”. This practice has been in place for my entire career and rarely gets challenged. However, in recent years I have come across several scenarios where either the facility/unit designed the process to function this way or operations have learned how they can operate the process this way. In a lot of the cases, staffing cuts have led to these results.
The design basis for secondary containment comes from several sources. The two that I will reference are IFC and OSHA:
1910.106 states…