Spill risks lurk in all kinds of places around machining and fabrication facilities, and Andy James has a way to track them and ultimately solve them.

In 2017, he developed what he calls a spill risk algorithm and has since gathered information from tens of thousands of site visits. The data shows where facilities tend to do well with spill risk—and where they fall short. “It’s not only single-purpose sites, like machine shops,” says James, who is vice president and chief marketing officer of New Pig, maker of industrial leak and spill prevention products. “We see these types of risks at large manufacturers as well.”

Here, James explains seven areas of highest spill risk revealed by years of data, along with solutions to help employers manage their risk to avoid costly fines and environmental damage.

1. Missing or Empty Spill Kits

Data point: “The No. 1 risk that we see across all facilities is either not having a spill kit where you should, or having a spill kit and it being pilfered or empty.”

Discussion: James says, “Spill kits being raided is virtually always because there aren’t enough incidental-use absorbents around.” Consequently, when a serious spill occurs, the necessary supplies aren’t there.

Solution: James recommends putting a bale of incidental-use absorbents right on top of the spill kit. That way, workers take from the bale for quick spills instead of going into the spill kit. Also, safety managers can quickly see whether the spill kit has been used. “That bale of mats on top is kind of like a fuel gauge,” he says.

Read more: What You Should Know About Choosing an Absorbent Sock

2. Spill Kits Not Matching the Spill Plan

Data point: “More than two-thirds of machining and fabrication facilities have inadequate spill kit coverage versus what they’ve stated in their spill plan.”

Discussion: A facility’s spill plan lays out the location of spill kits and the steps to take after an emergency spill. “If your spill plan says, ‘We respond to all spills over 10 gallons with spill kits in appropriate areas,’ now I’m looking for everywhere that you have over 10 gallons of liquid stored, and I’m trying to find the spill kit,” James says.

Solution: Mismatching spill plans are easy for regulatory inspectors or auditors to spot, and thankfully, just as easy for facilities to remedy. “At some machining operations, maybe it’s easier to stash a 5- or 10-gallon spill kit at each workstation. Some might like to have higher-capacity spill kits out on the edges of the machining floor,” James says. “All are perfectly valid.”

3. Incomplete Secondary Containment

Data point: “About 90 percent of machine shops and fabrication operations have incomplete spill containment pallet coverage.”

Discussion: Whether they’re widely distributed on the floor or concentrated at a dedicated drum storage, James finds that in many facilities, some drums sit on secondary containment pallets, while others don’t. That’s a red flag for inspectors.

Solution: “Make sure you have consistent spill pallet coverage,” James says. Containment pallets are about 6 to 12 inches high and hold up to four drums; they’re designed to be moved around. Decks, on the other hand, have a lower profile and can be connected to hold more drums in a wider area—at a lubricant dispensing station, for example.

Read more: Shedding Light on SPCC Secondary Containment Requirements

4. Outdoor and Perimeter Risks

Data point: “Across all facilities we work with, the perimeter and storm drains are virtually always a high measured risk.”

Discussion: James explains, “Safety folks tend to think of what’s going on in the facility. Where we see the risk is the perimeter of the facility and then just outside the facility—loading docks, storm drains, etc.” Many times, spills happen close to drains, requiring quick action and the right product.

Solution: For these situations, “drain covers really shine,” James says. “If you need to lock down that drain, you’re grabbing the drain cover—ideally, it’s stored outdoors or right at the edge of the facility—you’re throwing it down, and now that drain is liquid-tight.”

5. Unused Floor Drains

Data point: “64 percent of machining and fabrication operations have at least one critical or very high drain risk inside the facility.”

Discussion: The reason, James says, is often because machining operations are in mixed-use facilities, with floor drains installed on a grid. “Now, you’ve got lubricants, gear oils, hydraulics and coolants, in some cases within 10 feet of a floor drain,” he says.

Solution: If you aren’t using a floor drain, James strongly recommends either plugging it or covering it. “Urethane drain plugs can be installed at a moment’s notice and then pulled out if needed,” he says.

6. Rainwater From Scrap Piles to Storm Drains

Data point: “Under 5 percent of sites are addressing stormwater sheens at all, and even less for sheens starting at scrap piles.”

Discussion: James says, “You’ve got your scrap stored outdoors or even under a little roof on your back loading dock. It’s either getting direct rainfall or blown rain. That rain is washing the coolant and tramp oil off your chip pile, and then it is heading directly toward a drain.”

Solution: There are two categories of protection. “Above the drain, think filtration,” James says. “That would be for metal chips or swarf that in a heavy rain gets carried around the parking lot and washed to your storm drain.” Below the drain, consider a storm drain insert that passively “captures oily sheen all the time,” plus sediment, trash and debris, James says.

Read more: Are Pig Mats and Socks Reusable?

7. Exotics, Etchants and Samples

Data point: “We see a lot of sub-5-gallon quantities of liquids that just get stashed in a corner and kind of fly under the radar.”

Discussion: A CNC milling facility might have some ferric chloride or methyl ethyl ketone left over from odd jobs that finished years ago. Or, a company gave them a sample of a degreaser or solvent that’s no longer used. “Regardless of how the liquid found its way into the facility, it falls under right-to-know, and you still need to be able to respond to a spill,” James explains.

Solution: Proactive facilities will do an annual housecleaning, James says. “Let’s go through our liquids, make sure that we don’t have any 5-gallon containers that no one knows what they are. Let’s get them out and make sure we’re nice and tight on our liquids inventory,” he says. For liquids that you do need to keep around, make sure to have the right product on hand.