Sometimes there is a reason for crying over spilt milk, especially when it closes roads for several hours and pollutes the water supply, killing thousands of aquatic life and costing your company some hefty fines.
Milk has always been told to “do your body good,” but what most don’t realize is that it is also classified as a pollutant if it reaches surface waters during a spill. As the Environmental Protection Agency’s Section Chief in the Emergency Response group, Region 1, Ted Bazenas notes, “Milk is considered a pollutant primarily because as large volumes of milk breaks down in the water, it creates a high biological oxygen demand that could result in a fish kill.”
So was the case in 1996 when a spill in Minnesota killed thousands of fish and again in 2004 when 6,000 gallons of milk entered a lake, closing it for a whole year. In 2014, Philadelphia escaped the same fate when 6,000 gallons of milk spilled one mile from a creek. 1
“All kinds of oils, including animal fats and vegetable oils, have been considered oils under the Spill Prevention, Control, and Countermeasure (SPCC) rule based on the legislative definition of “oil” in the Clean Water Act,” explains Kimberly Staiger who is part of the EPA’s Office of Regional Public Liaison in Region 2. “Milk is considered an oil and its storage and handling have been subject to the SPCC rule, which is intended to prevent damage to the inland waters and shorelines of the United States. However, EPA is amending the SPCC rule to exempt milk and milk products containers and associated piping and appurtenances from the SPCC requirements. EPA is also removing the compliance date requirements for the exempt containers. The exemption will cover all containers, piping and appurtenances of milk and milk products. For example, milk products include cheeses, yogurts and ice cream. Additionally, transfers and milk handling associated with these containers and appurtenances are exempt from the SPCC requirements. EPA is finalizing this exemption because we believe that milk production is already subject to other standards and requirements that will help prevent spills.”
Bazenas adds, “Milk was initially regulated under SPCC and FRP regulations as an AFVO because of its fat content. It was determined that storage of milk is adequately regulated by the FDA. As a food for human consumption, FDA regulations are very stringent regarding storage, etc.”
In the event that milk or milk products are spilled into a waterway, Staiger notes that it must be reported to the National Response Center (NRC) at 800-424-8802 or (202) 426-2675, which is staffed 24 hours per day by U.S. Coast Guard personnel.
“If a spill of a large volume of milk (several thousand gallons) were to occur, the response protocols are to prevent the release from entering any water body by physical methods such as collecting pooled liquids, plugging storm drains, etc.,” states Bazenas. “If the spill reached the water, regulatory agencies, both state and federal, would be monitoring for oxygen levels and could perhaps attempt to aerate the waters if oxygen levels dropped too low. However, the most important actions would be to prevent the release from reaching water in the first place.”
For more information on the Spill Prevention, Control and Countermeasure (SPCC) Rule click here.