When do you have to call the National Response Center about a spill, and what SPCC records do you keep?

General information, not legal advice.

The short answer

Two different federal rules come up when something spills at work. They ask for different things.

1. The call (40 CFR 302.6). When a release of a hazardous substance reaches that substance's reportable quantity within 24 hours, the person in charge must notify the National Response Center immediately, at 1-800-424-8802.
2. The records (40 CFR 112.7). If your facility has an SPCC (Spill Prevention, Control, and Countermeasure) plan for oil storage, keep the records of its inspections and tests with the plan, for 3 years.

The first is a notification rule, not a records rule. The second is a records rule. Both lines are short summaries, not the rules' own words. The rest of this guide takes them one at a time.

Rule 1: calling the National Response Center

What the rule asks. The person in charge must notify the National Response Center immediately when a release of a hazardous substance reaches its reportable quantity within 24 hours.

This is a summary. The rule has its own exact wording and may not cover every release; this guide does not list who it applies to in detail or any exceptions. Read 40 CFR 302.6 itself before deciding a release does or does not need a call.

The reportable quantity depends on the substance. There is no single number. EPA keeps a list of hazardous substances and their reportable quantities. We did not read that list for this guide, so look up the current list yourself for each substance you keep, before anything spills, so nobody is looking it up in the middle of a cleanup.

Practical habits (ours, not the rule's):

• Keep the number, 1-800-424-8802, where the people who would be in charge of a spill can find it without searching.
• Decide ahead of time who counts as "in charge" on each shift, so nobody assumes someone else made the call.
• Treat "immediately" as meaning the call comes first. The written account can follow.
• Write down, at the time: when the release was noticed, what it was, roughly how much, where, who called, when they called, and any reference you were given.
• If you decide a release did not need a call, write down why, with the amount and how you worked it out.

The rule is about the call, not a record of it. A note made at the time is what lets you show, later, that the call happened and when.

Rule 2: SPCC inspection and test records

What the rule asks. A facility with an SPCC plan keeps the records of the plan's inspections and tests with the plan, for 3 years.

This is a summary of one part of the rule. Read 40 CFR 112.7 and your plan for anything else it asks of these records, such as how they are done and signed.

What this guide does not cover. Which facilities need an SPCC plan, and which inspections and tests it calls for and how often. Start from your plan.

Practical habits (ours, not the rule's):

• Keep a list of every inspection and test your plan calls for. That list is your schedule.
• Write one record per inspection or test, with the date it was done and who did the work. Follow the rule and your plan for anything else each record needs, such as a signature.
• Store the records with the plan, as the rule asks.
• Keep each record at least 3 years. Check the rule for when the 3 years start before throwing anything away.

What we did not check

• Oil spills and the National Response Center. Rule 1 above is about hazardous substances. Whether an oil spill must be reported, and to whom, is a separate question we did not check.
• Reportable quantities. We do not list any; look the substance up in EPA's list of reportable quantities. We did not read that list for this guide.
• Exceptions and details. Who exactly the 302.6 duty applies to, any releases it leaves out, and how SPCC records must be done and signed under 112.7. Read the rules.
• State and local rules. Not researched; check yours separately.

Checklist

What the rules ask (as summarized above; read the rules themselves):

• A call to the National Response Center, 1-800-424-8802, immediately, when a release of a hazardous substance reaches its reportable quantity within 24 hours
• If you have an SPCC plan: its inspection and test records kept with the plan for 3 years

Good habits (ours, not the rules'):

• The National Response Center number posted where the people in charge can find it
• A named person in charge for each shift or site
• The reportable quantity looked up, in advance, in EPA's list for each hazardous substance you keep
• Every spill written down at the time: what, how much, where, when noticed
• For each call: who called, when, and any reference given
• For each release not called in: the amount and the reason, written down
• If you have an SPCC plan: a list of its inspections and tests, each one recorded with the date and who did the work
• Mistakes fixed with a new, dated correction, never by changing the old record
• Oil spill reporting and state and local rules checked separately

How Cibotti helps

Cibotti does not make you compliant with anything. It helps you keep these records and prove, later, that they say what they said on the day they were written.

• A spill entry with the rules beside it. Choose Spill / Release as the report type and the Oversight box summarizes what the federal rules above say, including that the reportable quantity depends on the substance. Staff can type or speak the account, and attach a photo or file; its fingerprint is kept with the entry.
• Changes show. When a record is saved it gets a fingerprint and is chained to the one before it. Every 10 minutes the newest fingerprint is sent for a Bitcoin timestamp, which Bitcoin confirms some hours later. Once an entry is covered, any change to it shows when the chain is checked. There is no edit button: a correction is a new entry.
• A routine for each SPCC inspection. Set a routine for each inspection or test (every so many days, weeks or months, or every weekday), and a manager can give it to the person responsible. Cibotti shows what is due and overdue, tracks whether each was done on time, and can email that person a reminder on the due day and the day after a miss (once they have confirmed an email address).
• A second look at spills. The Bird's-Eye Summary points out spill entries whose text does not say anyone was told. It says what it did not find in Cibotti, never that a rule was broken.
• Ready to show. Filter All entries by type and date, then export to CSV or JSON or print a report. An outside contractor can confirm a record through a one-time link, with no account.

Sources

The rule details in this guide come from the official text, read on 2026-10-08. Each link opens the current official text in a new tab; check it there before you rely on a detail.

• 40 CFR 302.6 on eCFR (opens in a new tab): notifying the National Response Center.
• 40 CFR 112.7 on eCFR (opens in a new tab): SPCC inspection and test records.

Try it

Open the live demo at https://cibotti.app ("Open the live demo") and see how a record is sealed. There is no edit button; corrections are new entries. If you add a sample entry there, use made-up details: the demo company is shared, and entries in it are permanent.

John, Cibotti