EHS Compliance by Industry: Which Inspection Programs Apply to Your Facilities

Quick answer: Your EHS inspection program list comes from what your facility stores, what it can leak, and what rain touches on site, more than from your industry label. Store more than 1,320 gallons of oil aboveground and you need a Spill Prevention, Control, and Countermeasure (SPCC) plan. Run equipment that handles volatile organic compounds and you may need Leak Detection and Repair (LDAR) monitoring, by instrument or by optical gas imaging (OGI). Expose industrial activity to stormwater and you need a permit. Generate hazardous waste and federal generator rules apply. Safety and fire inspections apply almost everywhere.

This guide is for EHS managers and facility leads who want a straight answer to “which of these do we actually have to run?” It covers eight industries, the trigger behind each program, and what running it looks like in the field.

Regulatory details checked against the eCFR in October 2026. This is general information, not legal advice. Your permits and your state rules decide the final answer.

Table of Contents

1. The seven inspection programs and what triggers them
2. Which inspection programs apply in each industry
3. Oil and gas production
4. Refineries and chemical plants
5. Electric utilities
6. Mining
7. Terminals, fleets, and depots
8. Automotive and manufacturing plants
9. Pulp, paper, and wood products
10. Commercial buildings
11. Different programs at different facilities
12. FAQ

The seven inspection programs and what triggers them

Every program below has a specific trigger. If you know the trigger, you can usually answer the applicability question for any facility in a few minutes.

Program	What triggers it	Core federal rule
SPCC	More than 1,320 gallons of oil in aboveground containers of 55 gallons or more, with a reasonable chance of reaching navigable waters	40 CFR 112
LDAR, including OGI surveys	Valves, pumps, and connectors in organic or hazardous air pollutant service at regulated sources, plus fugitive emissions monitoring at oil and gas well sites and compressor stations	Part 60 and Part 63 equipment leak subparts, 40 CFR 60 Subpart OOOOa and OOOOb
Stormwater	Industrial activity exposed to rain, or construction that disturbs 1 acre or more	Clean Water Act NPDES permits, federal or state
Waste	Generating hazardous waste, with rules scaled by monthly quantity	40 CFR 262
Safety	Workplace hazards, with inspection duties set by OSHA, MSHA, and your own program	29 CFR 1910, 30 CFR (mining)
Fire	Extinguishers, sprinklers, alarms, hydrants, and exits	29 CFR 1910.157 and NFPA standards
Custom programs	Anything your permits, insurer, or corporate standards add	Varies

The one that catches people most often is SPCC. The 1,320-gallon count includes every aboveground oil container of 55 gallons or more: tanks, drums, generator day tanks, and oil-filled equipment like transformers. The main exclusions are permanently closed containers and motive power containers such as a truck’s own fuel tank.

Which inspection programs apply in each industry

This is the typical mix. A specific facility can land outside it, which is why the triggers above matter more than the industry name.

Industry	SPCC	LDAR	Stormwater	Waste	Safety	Fire
Oil and gas production	Usually	Usually	Sometimes	Usually	Usually	Usually
Refining and chemical	Usually	Usually	Usually	Usually	Usually	Usually
Electric utilities	Usually	Rarely	Sometimes	Usually	Usually	Usually
Mining	Usually	Rarely	Usually	Usually	Usually	Usually
Terminals, fleets, depots	Usually	Sometimes	Usually	Usually	Usually	Usually
Automotive and manufacturing	Often	Sometimes	Usually	Usually	Usually	Usually
Pulp, paper, and wood	Usually	Sometimes	Usually	Usually	Usually	Usually
Commercial buildings	Sometimes	Rarely	Rarely	Often	Usually	Usually

Usually means most facilities in the industry run the program. Often means many do. Sometimes depends on a specific trigger. Rarely means it’s the exception. The LDAR column includes both Method 21 monitoring and OGI surveys.

Oil and gas production

Onshore production runs the longest program list of any industry here. LDAR is the heavy one, and at well sites and compressor stations it takes the form of fugitive emissions monitoring. Under Subpart OOOOa, which covers sites built or modified between September 2015 and December 2022, well sites are surveyed at least semiannually and compressor stations at least quarterly. Operators can survey with OGI or with EPA Method 21, where a reading of 500 ppm or more counts as a leak. The first repair attempt is due within 30 days of finding the leak, and the repair must be finished within 30 days after that.

Newer sites fall under OOOOb, which tightens monitoring further, and existing sites will come under state plans built on the OOOOc guidelines. Several OOOOb deadlines moved during 2025 rulemaking, so check the current eCFR before you set a schedule. Our OOOOa LDAR and OGI guide walks through the monitoring plan in more detail.

SPCC comes next, and production sites cross the threshold fast: a single 400-barrel tank holds 16,800 gallons. Stormwater is the surprise in the other direction. The Clean Water Act exempts most uncontaminated stormwater from oil and gas exploration, production, and processing, including site construction, so federal industrial permits often don’t apply. Contaminated runoff and some state programs still do. Waste has a similar split: drilling fluids and produced water are exempt from federal hazardous waste rules, but shop solvents and paint waste are not.

The practical problem is distance. A well site might be an hour’s drive from the office with no cell signal. EHSTracks runs inspections on iOS and Android apps that work fully offline and sync when you’re back in range. Every inspection point sits on a patented satellite map, and patented GPS distance checks require a written justification when an inspector is too far from the point. LDAR in EHSTracks covers both Method 21 and OGI inspections on that same platform. See oil and gas EHS compliance software for the product view.

Refineries and chemical plants

A refinery runs every program on the list, and LDAR sets the pace. Refineries fall under NESHAP Subpart CC, which points existing sources to the Part 60 Subpart VV equipment leak rules and new sources to Part 63 Subpart H. In practice that means thousands of tagged components, periodic Method 21 monitoring, a first repair attempt within 5 days of finding a leak, and a completed repair within 15 days. Delay of repair (DOR) is allowed when a fix needs a unit shutdown, but it has to be documented.

OGI has a place in refinery LDAR too. The alternative work practice in 40 CFR 60.18(g) lets operators use OGI in place of Method 21, with its own survey frequencies and recordkeeping. Many plants still run Method 21 and use OGI cameras to find leaks between rounds.

EHSTracks was built around this workload. The LDAR product inspects every component in a zone on one screen, requires a background reading before Method 21 readings start, records a leak automatically when a reading exceeds your leak definition, and tracks the 5-day and 15-day deadlines, DOR, and follow-up monitoring (FUM). A guided four-step calibration wizard links each calibration to every Method 21 inspection active at the time.

The commercial overview is at EHS software for refineries and chemical plants. For the program checklist, read refinery EHS programs explained.

Electric utilities

Utilities need SPCC more often than they expect, because transformer oil counts. A large power transformer can hold thousands of gallons, so one substation can cross 1,320 gallons on its own. The rule gives some relief: qualified oil-filled operational equipment can use an inspection program and a contingency plan instead of secondary containment, under 40 CFR 112.7(k). That relief still requires an SPCC plan and documented inspections.

Stormwater depends on the site. Generating stations typically need industrial stormwater coverage, substations usually don’t, and any construction that disturbs an acre or more needs a construction permit. Waste is mostly maintenance streams: used oil, batteries, lamps, and solvents. Safety and fire inspections run at every staffed facility.

The workload is spread thin across many small sites, which suits a map-based app. EHSTracks shows every substation and inspection point on one satellite map, runs each schedule automatically, and works offline at the sites with no signal. The stormwater and SPCC product pages cover the two programs utilities ask about most.

Mining

Mining combines remote sites with heavy environmental exposure. Stormwater is usually central: active and inactive mines need industrial stormwater coverage, and some mine drainage is regulated as process water under effluent guidelines instead. SPCC applies to fuel and lubricant storage for the haul fleet. The trucks’ own fuel tanks don’t count toward the threshold, but the tanks that fill them do.

Mining waste has its own exemption for extraction and beneficiation wastes, but the maintenance shop generates regulated hazardous waste like any other industrial site. Safety is the daily program. At metal and nonmetal mines, the Mine Safety and Health Administration (MSHA) requires a competent person to examine each working place at least once per shift, which makes a reliable checklist tool part of the job.

Offline isn’t a nice-to-have in a pit or underground. EHSTracks inspections work with no connectivity, and the waste product tracks containers, versioned waste profiles, and required ship dates. See mining EHS inspections that work offline and our explainer on hazardous waste tracking software.

Terminals, fleets, and depots

A bulk fuel terminal is an SPCC facility first. Its storage runs well past the threshold, so the plan and its tank inspection schedule are the backbone of the program. Gasoline terminals also carry equipment leak inspections under their own air rules. Our breakdown of SPCC inspection requirements covers what those tank inspections involve.

Fleet depots look different. Vehicle maintenance and equipment cleaning areas trigger industrial stormwater coverage, and the shop generates used oil, spent solvents, and batteries. SPCC applies when bulk fuel and oil storage crosses 1,320 gallons, not counting the fuel in the vehicles themselves.

Rain events matter at both. EHSTracks runs post-storm event inspections alongside the recurring schedule, and several inspectors can work the same post-storm inspection at once. Any “No” answer creates a Repair with a responsible person and a due date. See EHS compliance for fleets, depots, and terminals.

Automotive and manufacturing plants

An assembly or parts plant usually runs stormwater, waste, safety, and fire, with SPCC for fuel, hydraulic oil, and lubricant storage. Waste is the big one. Paint shops and solvent cleaning can put a large plant in the large quantity generator category, which means waste must ship within 90 days. LDAR applies only where a specific chemical-process rule reaches the plant, so check your air permit rather than assuming.

Plants run around the clock, and the inspector on the night shift is rarely the person who set the schedule. EHSTracks opens and closes inspection windows nightly in each facility’s local timezone and tracks hazardous waste generated by month, quarter, and year, with monthly generator status emails. See automotive plant EHS compliance.

Pulp, paper, and wood products

Mills and wood products plants are stormwater-heavy. Log yards, chip piles, and outdoor material handling mean large exposed areas, so industrial stormwater permits and their routine inspections are a core program. Waste spans mill chemicals, maintenance streams, and lab waste, and SPCC applies to fuel and the large volumes of hydraulic and lubricating oil in mill equipment.

Fire risk is higher than in most industries. Wood dust and stored material drive frequent extinguisher, sprinkler, and alarm checks, and NFPA 664 addresses fire and explosion prevention in wood processing. Some mill processes carry leak inspection duties under their air permits, which is why LDAR reads “Sometimes” in the table.

EHSTracks runs the fire schedule, the stormwater routine inspections, and the post-storm inspections on the same app. See paper mill and wood products EHS.

Commercial buildings

Commercial buildings are mostly fire and safety. Under 29 CFR 1910.157, portable extinguishers need a monthly visual inspection and an annual maintenance check, and NFPA standards set the schedules for sprinklers, alarms, and exit hardware. Waste is usually limited to universal wastes like lamps and batteries.

SPCC is the one property managers miss. A building with a 1,000-gallon generator tank and a 400-gallon day tank holds 1,400 gallons, which is over the threshold if a spill could reach a storm drain that flows to a waterway. Most urban buildings meet that condition.

EHSTracks’ Fire product covers extinguishers, suppression systems, hydrants, alarm panels, and emergency exit hardware, and the SPCC product tracks the tank inspections. See commercial building compliance.

Different programs at different facilities

Corporate EHS teams rarely manage one kind of site. A typical portfolio might include a refinery, two terminals, a dozen service centers, and a plant in another state, each with a different program mix.

EHSTracks is set up facility by facility. Each facility gets only the products it needs: SPCC, LDAR (including OGI), Stormwater, Waste, Safety, Fire, or FLEX. Each runs its own schedules in its own timezone, and email notifications can summarize every facility a user is responsible for. See multi-facility EHS compliance for corporate teams, or start with what EHS software you actually need.

Some programs don’t fit a standard category: refrigerant leak inspections, tank integrity walkdowns, an insurer’s checklist. FLEX runs those as configurable inspection programs on the same offline platform. Our guide to refrigerant leak repair requirements is a worked example.

FAQ

Does transformer oil count toward the SPCC threshold?

Yes. Oil-filled operational equipment such as transformers and circuit breakers counts toward the 1,320-gallon aggregate threshold in 40 CFR 112.1. It isn’t bulk storage, so qualified equipment can use an inspection program and contingency plan under 112.7(k) instead of secondary containment. The facility still needs an SPCC plan.

Can optical gas imaging replace Method 21?

Often, yes. Subpart OOOOa lets oil and gas operators survey with either OGI or Method 21. Refineries and other sources under Method 21 rules can use OGI through the alternative work practice in 40 CFR 60.18(g), which has its own survey frequencies and recordkeeping. Check your permit before switching methods.

Do oil and gas sites need an industrial stormwater permit?

Usually not at the federal level. The Clean Water Act exempts uncontaminated stormwater from oil and gas exploration, production, processing, and transmission, including site construction. Coverage is required when runoff becomes contaminated, and some states set their own requirements, so check with your state permitting authority.

What hazardous waste generator category am I?

It depends on monthly quantity. Very small quantity generators produce 100 kg or less of hazardous waste per month. Small quantity generators produce more than 100 kg but less than 1,000 kg. Large quantity generators produce 1,000 kg or more, or more than 1 kg of acute hazardous waste. Your category sets how long waste can stay on site.

How often do fire extinguishers need to be inspected?

OSHA requires a monthly visual inspection of every portable fire extinguisher and an annual maintenance check, with the annual date recorded (29 CFR 1910.157). NFPA 10 adds detail on what each inspection covers. Sprinklers, alarms, and hydrants follow their own NFPA schedules.

Can one EHS platform handle facilities in different industries?

Yes, if it’s configured per facility. In EHSTracks, each facility runs only the products it needs, such as SPCC at a terminal and LDAR at a refinery, with schedules in each facility’s local timezone. Reports run per product, and email notifications can summarize all of a user’s facilities.

Does EHS inspection software work without cell service?

EHSTracks does. The iOS and Android apps download a full copy of the facility’s data, so inspectors can inspect, record answers, and calibrate equipment with no signal. Changes upload automatically when the device reconnects. That matters at well sites, substations, and mines where coverage is unreliable.

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Not sure which inspection programs apply to your facilities? We can walk through your sites with you and map each one to the programs it needs. Talk to the EHSTracks team.