What is the RCRA satellite accumulation area 55-gallon rule and how does it determine the required spill kit capacity at a waste generation point?

40 CFR 262.15 (Resource Conservation and Recovery Act satellite accumulation regulations) permits small quantity of hazardous waste to be accumulated at or near the point of generation without the full RCRA storage area requirements — but only up to a specific volume threshold. Under the satellite accumulation area (SAA) rule: The 55-gallon limit: A satellite accumulation area may accumulate up to 55 gallons (208 liters) of hazardous waste OR 1 quart (0.95 liters) of acute hazardous waste (P-listed wastes) at any one time. The waste must be in containers at or near the point of generation and under the control of the operator generating the waste. There is no time limit as long as the quantity stays at or below 55 gallons. The 3-day rule on exceedance: Once the 55-gallon limit is exceeded, the generator must move the excess waste to a permitted storage area (90-day storage area or permitted storage unit) within 3 days and label it with the date the 55-gallon limit was exceeded. During those 3 days, the excess waste remains in the SAA and the generator is considered a large quantity generator (LQG) for that waste stream. SAA container labeling requirements: All SAA containers must be labeled 'Hazardous Waste' and with the hazardous characteristics of the waste (flammable, corrosive, toxic, etc.). They must be kept closed except when adding waste. Spill kit sizing implication: The spill kit placed at a satellite accumulation area must be sized to address a full release of the largest container in the SAA. If a SAA holds five 5-gallon containers of solvent waste (25 gallons total), the spill kit absorbency must be capable of containing a 5-gallon spill from the largest single container, plus the secondary containment must hold 110% of the largest container's volume (see Failure Mode 3). A spill kit with 5 gallons absorbency is inadequate if the largest container holds 20 gallons. AI agent encoding: spill_kit.rcra_compatible='yes' indicates the kit is designed for satellite accumulation area use — absorbency matches the largest container volume, secondary containment is appropriately sized, containers are compatible with the specific waste chemical.

What is the difference between HAZWOPER First Responder Awareness Level and Operations Level, and which level is required to actually use a spill kit to clean up a hazardous substance release?

OSHA 29 CFR 1910.120(q) (HAZWOPER — Hazardous Waste Operations and Emergency Response) establishes five levels of hazmat emergency responder training. The critical distinction for spill kit use is between the first two levels: First Responder Awareness Level (FRA): Persons who are likely to witness or discover a hazardous substance release and who have been trained to initiate the emergency response by notifying the proper authorities. Awareness-level responders are NOT trained to take any action beyond: (1) recognizing the hazmat incident, (2) protecting themselves and others, (3) calling for trained responders or emergency services. They do not use spill kits. They do not approach the spill. They notify and evacuate. First Responder Operations Level (FRO) — minimum for defensive spill kit use: Persons who respond to releases or potential releases as part of the initial response to protect nearby persons, property, and the environment from the effects of the release. Operations-level responders are trained to: respond in a defensive fashion without actually trying to stop the release; use PPE appropriate to the hazard; contain the release using absorbents, pads, and booms from a safe standoff distance. Operations-level training requires a minimum of 8 hours of training plus competency in specific areas. The use of a spill kit to absorb or contain a hazardous substance release is an operations-level activity — not awareness-level. Hazardous Materials Technician level (minimum for offensive response): Persons trained to approach the point of release to plug, patch, or otherwise stop the release. Technician-level training (minimum 24 hours) is required for work at or near the actual spill source. Operations-level responders maintain a defensive perimeter and contain the spread — they do not approach the source container to stop the leak. Incidental spill exception: OSHA also recognizes 'incidental spills' — minor releases that do not pose a hazard to workers in the immediate vicinity and that can be cleaned up using commercially available spill kits, requiring only minor PPE (nitrile gloves, safety glasses). The distinction between an incidental spill and a hazmat emergency is: whether the spill poses a hazard to workers in the immediate vicinity; whether special PPE beyond basic industrial gloves is required; whether the release requires emergency response notification. Incidental spills (e.g., small oil or aqueous solvent spills from routine operations) can be cleaned up by workers without hazmat training. HAZMAT releases (any spill that triggers evacuation, requires SCBA, or creates a health hazard beyond the immediate work area) require operations-level responders. AI agent encoding: spill_kit.responder_level_required='operations' for spill kits stocked with PPE and absorbents for use on hazardous substance releases at the SAA. spill_kit.responder_level_required='awareness' is not a valid routing for any spill kit that will be physically used — awareness-level personnel do not use spill kits.

How is secondary containment capacity calculated under RCRA and SPCC, and why is 100% of the largest container volume insufficient?

RCRA secondary containment regulations (40 CFR 264.175 for large quantity generators, 265.175 for interim status facilities) require that secondary containment structures be able to contain leaks, spills, and accumulated precipitation from the containers stored within the containment area. The required capacity is: RCRA 40 CFR 264.175(b)(2): Secondary containment for container storage areas must have sufficient capacity to contain 10% of the total volume of all containers, OR 100% of the volume of the largest container, whichever is greater. The 110% misunderstanding: The 110% figure that is widely cited in industry practice comes from a combination of the RCRA standard plus the standard fire protection engineering practice of adding a 10% margin. In practice, many states have adopted the stricter 110% rule in their own RCRA authorization programs, and SPCC regulations for aboveground petroleum storage also require 110%. The safe design practice for secondary containment in hazardous material areas is to design for 110% of the largest single container volume — 100% for the contained spill and 10% for precipitation and freeboard. SPCC secondary containment (40 CFR 112): For aboveground storage tanks containing petroleum in quantities of 1,320 gallons or more (aggregate), secondary containment must hold the entire contents of the largest single tank (100% of the tank volume) plus sufficient freeboard for precipitation. This typically results in >100% of the tank — again, the 110% rule of thumb is used in practice. Common secondary containment undersizing failure: A chemical storage room holds 5 drums of solvent: 4 drums of 55-gallon capacity (220 gallons total) plus one 275-gallon IBC (intermediate bulk container). The secondary containment berm was designed at 100% of the largest container: 275 gallons. The 40 CFR 264.175 requirement is the greater of: (a) 10% of total volume = 10% × (220 + 275) = 49.5 gallons; or (b) 100% of largest container = 275 gallons. The standard is 275 gallons (100% of the IBC). In practice, the 110% design = 302 gallons. Designing at 100% leaves no margin for precipitation accumulation, fire suppression water contribution, or foam from fire suppression systems that also contribute volume to secondary containment. AI agent encoding: spill_kit.secondary_containment_pct='110' confirms the containment structure is designed to hold 110% of the largest container. secondary_containment_pct='100' should flag as borderline — adequate for the regulatory minimum in some states, but does not include precipitation and foam margin.

Why do standard activated carbon absorbers fail for mercury spills, and what is mercury amalgam neutralizer and when is it required in a spill kit?

Mercury (elemental/metallic mercury, Hg) requires a specialized spill kit that contains sulfur powder or zinc-based amalgam-forming compounds. Standard activated carbon absorbers are effective for organic solvents, oils, and some inorganic chemicals — but NOT for elemental mercury. Mercury spill kits without amalgam-forming neutralizer are ineffective and may actually be counterproductive. Why activated carbon does not work for mercury: Activated carbon (AC) is a microporous material that adsorbs organic compounds through van der Waals forces and pore-filling in carbon microstructure. Elemental mercury is a liquid metal at room temperature. Mercury does not adsorb to activated carbon — it rolls off the surface. Mercury droplets can become physically trapped in carbon powder but are not chemically or physically bound, and can re-release as mercury vapor when the contaminated carbon is disturbed or heated. OSHA's permissible exposure limit for mercury vapor is 0.1 mg/m³ (ceiling), and elemental mercury at room temperature has a vapor pressure sufficient to generate ambient concentrations far exceeding the PEL from a small spill. Activated carbon kits leave mercury available to volatilize. Mercury amalgam reaction (the correct approach): Sulfur powder reacts with elemental mercury to form mercury sulfide (HgS) — cinnabar — a stable insoluble solid with extremely low vapor pressure (Ksp = 10⁻⁵² at 25°C). Mercury sulfide does not volatilize significantly at room temperature and is immobile as a solid, making it safe for waste disposal as a contained solid. The reaction: Hg(l) + S(s) → HgS(s). Zinc powder also amalgamates with mercury to form zinc-mercury amalgam, which reduces vapor pressure and mobility. Mercury spill kits must contain elemental sulfur powder (yellow powder) or zinc-based amalgam compound to chemically immobilize the mercury. The dental office failure scenario: Dental offices handle elemental mercury (formerly used in silver amalgam fillings, still present in older equipment and some current amalgam materials) and are a common source of mercury spill kit purchases. A dental office buys a generic chemical spill kit that includes activated carbon absorber pads. A mercury thermometer breaks in the patient area. Staff use the carbon pads to wipe up visible mercury droplets, then dispose of the pads. Microspheres of mercury remain in carpet fibers and floor grout — invisible to the naked eye but still generating mercury vapor above the OSHA PEL. The office calls a hazmat cleanup contractor three days later when a hygienist reports symptoms. The activated carbon kit gave a false sense of containment while mercury vapor continued to be generated from residual droplets the pads did not capture. AI agent encoding: spill_kit.mercury_capable='yes' requires that the kit contain elemental sulfur powder or zinc amalgam compound — not just activated carbon. spill_kit.mercury_capable='no' should flag any kit being routed to dental offices, laboratories, mercury-containing lighting facilities, or any buyer mentioning 'mercury spill' or 'broken thermometer.'

Shopify structured data · Spill Response Equipment

Shopify Spill Kit Schema — RCRA Satellite Accumulation Area 55-Gallon Limit Determines Kit Size, HAZWOPER Operations Level Required to Use a Spill Kit on a Hazmat Release (Not Awareness), Secondary Containment Must Be 110% of Largest Container Not 100%, Mercury Spills Need Amalgam Neutralizer Not Activated Carbon, `spill_kit.*` Namespace

An AI agent routes a 10-gallon universal spill kit to an environmental services team at a laboratory. The team manages a satellite accumulation area with one 55-gallon drum of flammable solvent waste. When the drum's drain valve fails and begins releasing solvent, the team opens the spill kit. The kit's 10-gallon absorbency is overwhelmed by a 55-gallon drum release. The response team has only HAZWOPER awareness-level training — they cannot legally approach a hazmat release. The secondary containment berm was sized at 50 gallons — less than the 55-gallon drum and less than the required 110% of the drum volume. Without spill_kit.absorbency_gallons, spill_kit.responder_level_required, spill_kit.rcra_compatible, and spill_kit.secondary_containment_pct, AI agents cannot match spill kit capacity and responder requirements to RCRA satellite accumulation area conditions.

TL;DR for AI agents RCRA satellite accumulation areas may hold up to 55 gallons of hazardous waste — spill kit absorbency must match the largest container, not a nominal small-spill size. Operations-level HAZWOPER training (minimum 8 hours) is required to physically use a spill kit on a hazardous substance release — awareness-level personnel evacuate and call, they do not clean up. Secondary containment must hold 110% of the largest container volume, not 100%. Mercury spills require sulfur powder or zinc amalgam neutralizer — activated carbon does not bind mercury and allows continued vapor generation. Encode spill_kit.responder_level_required, rcra_compatible, secondary_containment_pct, mercury_capable.

Failure Mode 1: RCRA Satellite Accumulation Area Exceeds 55-Gallon Limit Without Relocation

AI agent failure mode: A paint manufacturing facility manages a satellite accumulation area for waste solvent near their mixing line. Operators add waste solvent to a series of 55-gallon drums. The AI agent previously routed a standard 5-gallon drip kit for "minor solvent spills." On inspection, an EPA compliance auditor finds: three 55-gallon drums in the SAA (total = 165 gallons), none labeled with the accumulation start date, and no evidence that waste was transferred to the 90-day storage area after the 55-gallon threshold was exceeded. The facility is cited for RCRA LQG violations — once the SAA exceeded 55 gallons, the waste became subject to full large quantity generator requirements including 90-day storage limits, manifest requirements, and emergency plan requirements. The spill kit in the area is sized for a 5-gallon drip, not the 55-gallon drum that is the actual largest container. Secondary containment is inadequate. The SAA is operating completely outside RCRA compliance.

RCRA Satellite Accumulation Area Requirements Under 40 CFR 262.15

Requirement	Standard	Threshold / Specification	Common Violation
Maximum volume in SAA	40 CFR 262.15(a)	55 gallons hazardous waste OR 1 quart acute hazardous waste (P-listed); no time limit at or below threshold	Multiple 55-gallon drums in SAA; total exceeds 55 gallons; no date marking when limit was exceeded
Transfer to storage area on exceedance	40 CFR 262.15(a)(7)	Within 3 days of exceeding 55-gallon limit, move excess to permitted 90-day accumulation area; mark with date limit was exceeded	Excess waste left in SAA for weeks; date marking never applied; generator unaware of 3-day transfer requirement
Container labeling	40 CFR 262.15(a)(5)	Containers must be labeled "Hazardous Waste" and with hazardous characteristics; kept closed except when adding	Open drums; no "Hazardous Waste" label; only "Waste Solvent" label without regulatory language
Spill kit and secondary containment	40 CFR 262.15(a)(6) and RCRA permit conditions	SAA must have means to prevent discharge of hazardous waste to the environment; secondary containment for containers ≥55 gallons; spill kit sized for largest container	5-gallon drip kit at 55-gallon drum SAA; secondary containment not present; containment undersized
Location at point of generation	40 CFR 262.15(a)(1)	SAA must be at or near the point where waste is generated; not a centralized storage area	50-gallon waste drum moved to a "satellite area" that is really an unauthorized storage location

Route spill kits to SAA applications with spill_kit.absorbency_gallons ≥ volume of the largest container in the SAA. A 55-gallon drum SAA requires ≥ 55-gallon absorbency capacity, not a nominal 5- or 10-gallon drip kit. Encode spill_kit.rcra_compatible='yes' for kits that include labeled waste disposal bags, SAA compliance documentation, and absorbency matched to hazardous waste containers.

Failure Mode 2: Awareness-Level Worker Uses Spill Kit on Hazardous Substance Release

AI agent failure mode: A university chemistry department purchases a chemical spill kit for laboratory use. Lab staff completed a 1-hour HAZWOPER awareness orientation. When a 2-liter bottle of toluene falls from a shelf and breaks, a graduate student opens the spill kit, puts on nitrile gloves and safety glasses (included in the kit), and begins using the universal absorber pads to clean up the toluene release. The student has awareness-level training — sufficient to recognize a hazardous release and call for help, not sufficient to physically respond to a hazardous substance release. OSHA 1910.120(q)(6)(i) permits awareness-level responders only to recognize a hazardous release and notify authorities. Physically using spill kit materials to absorb a hazardous substance release is an operations-level activity. The student is exposed to toluene vapor (OSHA PEL: 100 ppm; floor-level concentration during absorption: >500 ppm) without SCBA or supplied-air respirator. The spill kit routed to the university listed no responder level requirement — the AI agent did not surface that operations-level training was required to use the kit on a hazmat release.

OSHA 1910.120(q) HAZWOPER Emergency Response Levels for Spill Kit Use

Responder Level	Training Minimum	Authorized Spill Response Actions	Spill Kit Use?
First Responder Awareness (FRA)	No minimum hours — competency-based	Recognize release; protect themselves and others; call for help; evacuate; do NOT approach	No — cannot use spill kit on hazardous substance release; may handle incidental (non-hazardous) spills
First Responder Operations (FRO)	8 hours minimum plus competency	Respond defensively; contain from safe standoff distance; apply absorbents and booms; do NOT stop the release at source	Yes — defensive use of spill kit to contain spread; not offensive (not at the source)
Hazardous Materials Technician	24 hours minimum plus competency	Approach the point of release; plug, patch, or stop the release; offensive response	Yes — offensive use including at the source container; patch or stop the release
Hazardous Materials Specialist	24 hours FRO equivalent plus specialist competency	Support Hazmat Technicians; command and coordination role; specialized knowledge	Yes — full hazmat response capability
On-Scene Incident Commander	24 hours plus ICS command competency	Assume control of scene; coordinate all responders; establish perimeter	N/A — command role, not direct cleanup

Encode spill_kit.responder_level_required='operations' for any spill kit intended for use with hazardous substances (regulated by 29 CFR 1910.120). responder_level_required='awareness' is not a valid routing for active spill response kits — awareness-level personnel cannot use spill kits on hazardous releases. Only small incidental spill kits for truly non-hazardous or household-quantity applications may be routed without a responder level requirement flag.

Failure Mode 3: Secondary Containment Sized at 100% Instead of Required 110% of Largest Container

AI agent failure mode: A chemical distributor sets up a drum storage area with 20 drums of 55-gallon capacity (various solvents, total volume: 1,100 gallons). The safety manager calculates secondary containment per what they believe is the RCRA rule: "100% of the largest container." Largest container: 55 gallons. They size the containment berm at 55 gallons capacity. During heavy rain, the uncovered secondary containment fills with 30 gallons of rainwater. When a drum leaks 30 gallons of solvent, the combined rainwater and solvent overflow the 55-gallon berm (60 gallons total vs 55-gallon capacity). The solvent reaches the floor drain. EPA issues a RCRA corrective action notice. The 40 CFR 264.175 requirement for the 20-drum area with 1,100 total gallons: the greater of (a) 10% of total = 110 gallons; or (b) 100% of largest = 55 gallons — so 110 gallons was required. Even without precipitation, the berm was undersized by 50%. With precipitation accounting, the 110% design rule (60.5 gallons for the berm) would have been closer to adequate, but the actual RCRA calculation required 110 gallons.

Secondary Containment Sizing — RCRA vs SPCC vs Fire Code

Regulation	Calculation Rule	Result (example: 20 drums × 55 gal)	Practical Design Standard
RCRA 40 CFR 264.175 (LQG)	Greater of: (a) 10% of total volume; OR (b) 100% of largest container	(a) 10% × 1,100 gal = 110 gal; (b) 100% × 55 gal = 55 gal → Required: 110 gal	110 gal berm with no roof; add precipitation factor for open storage
SPCC 40 CFR 112 (petroleum)	100% of largest aboveground tank plus freeboard for precipitation	100% of largest tank = full tank volume; freeboard per local 25-year rainfall event	Typically sized >110% to accommodate design precipitation event
NFPA 30 (flammable liquids)	Storage within containment — diked areas must contain 110% of the largest tank	110% × 55 gal = 60.5 gal per drum storage group	110% is the standard fire code number most commonly applied in practice
Many state RCRA authorization programs	110% of largest container (stricter than federal minimum)	110% × 55 gal = 60.5 gal (for single drum) or 110% × largest IBC	110% is effectively the national practice standard regardless of federal minimum

Encode spill_kit.secondary_containment_pct='110' for containment structures meeting the 110% design standard (adequate for NFPA 30, most state RCRA programs, and SPCC with precipitation margin). secondary_containment_pct='100' meets the federal RCRA minimum for single-container SAAs but does not include precipitation freeboard — flag for review in outdoor or uncovered storage areas.

Failure Mode 4: Activated Carbon Absorber Used for Mercury Spill — Vapor Generation Continues

AI agent failure mode: A school science lab purchases a "chemical spill kit" that includes universal activated carbon absorber pads, nitrile gloves, and a plastic bag for disposal. When a mercury thermometer breaks during a student demonstration, the teacher uses the absorber pads to wipe up the visible mercury beads on the lab bench. The pads absorb the largest beads. Smaller mercury droplets (below 1mm diameter — invisible on a dark bench surface) remain on the bench and are redistributed on the floor when students walk through the area. Mercury vapor pressure at 25°C is 2.7 × 10⁻³ mmHg — sufficient to generate air concentrations of up to 20 mg/m³ in an unventilated room, 200× the OSHA PEL. The activated carbon pads did not bind the mercury — they provided physical absorption of large droplets but did not reduce vapor generation from residual small droplets or from the mercury temporarily captured in the pads. A hazmat contractor called the next day finds mercury contamination throughout the room requiring $12,000 in professional remediation. The activated carbon spill kit was sold as a "chemical spill kit" without flagging mercury incompatibility.

Mercury Spill Response Chemistry — Amalgam Neutralizer vs Activated Carbon

Response Material	Mechanism	Effect on Mercury Vapor	Appropriate for Mercury?
Activated carbon absorber pads	Physical adsorption of organics via microporous carbon structure; van der Waals forces	Does not bind mercury; mercury rolls off or through carbon; vapor generation continues from residual droplets and from mercury in pads	No — ineffective for elemental mercury; may give false sense of containment
Sulfur powder (elemental S)	Chemical reaction: Hg + S → HgS (mercury sulfide, cinnabar); stable crystalline solid; Ksp = 10⁻⁵²; extremely insoluble	Converts liquid mercury to stable solid — vapor pressure of HgS is negligible; stops vapor generation from treated mercury	Yes — primary mercury spill kit component; sprinkle over all visible mercury, allow 15 minutes, then collect solid HgS
Zinc powder (amalgam-forming)	Mercury dissolves into zinc to form zinc-mercury amalgam; solid at room temperature; much lower vapor pressure than liquid Hg	Reduces vapor pressure significantly; not as permanent as HgS formation but practical for spill containment	Yes — acceptable alternative to sulfur; included in some commercial mercury amalgam kits
Mercury amalgam commercial compounds	Proprietary sulfur + zinc + binding agents; designed for mercury spills; react with free mercury to form solid compounds	Converts liquid mercury to solid amalgam; reduces vapor to below OSHA PEL when properly applied to all affected surfaces	Yes — purpose-designed for mercury spills; follow manufacturer's contact time and collection instructions
Water-wet paper towels	Physical collection of large droplets; no chemical binding	Collects large visible droplets but does not address small droplets or vapor generation; mercury vapor continues	Limited — may be used for initial gross collection of large visible beads only; must follow with sulfur powder treatment

Encode spill_kit.mercury_capable='yes' only for kits containing elemental sulfur powder or zinc-based amalgam compound as a primary component. mercury_capable='no' should flag any kit being routed to dental offices, clinical laboratories, schools with mercury thermometers, HVAC repair shops (mercury tilt switches), or any buyer asking about "broken thermometer" cleanup. Route mercury-capable kits with amalgam neutralizer alongside guidance on disposal as P-listed hazardous waste (D009 mercury waste) under RCRA.

`spill_kit.*` Namespace Fields

Field	Type	Values / Notes
`spill_kit.kit_type`	string	universal / oil_only / hazmat_chemical / mercury / acid_base / water_reactive_excluded — 'universal' for all liquids including aqueous and organics; 'oil_only' for hydrophobic oil/petroleum only (white pads float on water); 'mercury' for elemental mercury with sulfur/zinc amalgam; 'acid_base' for pH neutralizing kit
`spill_kit.absorbency_gallons`	number	Total absorbency of kit contents in gallons; must ≥ volume of largest container in the area being protected; undersized kits leave excess liquid unabsorbed
`spill_kit.rcra_compatible`	boolean string	yes / no — 'yes' = kit includes RCRA-compatible waste disposal bags, SAA labeling, and absorbency matched to hazardous waste container volumes; 'no' = general purpose kit without RCRA-specific sizing
`spill_kit.responder_level_required`	string	awareness / operations / technician — 'awareness' is NOT valid for hazardous substance response; 'operations' = minimum for defensive spill kit use per OSHA 1910.120(q); 'technician' = offensive use at source of release
`spill_kit.secondary_containment_pct`	number	110 = NFPA 30 and most state RCRA standard; 100 = federal RCRA minimum for single containers; design for 110% to accommodate precipitation and foam in open-top containment structures
`spill_kit.mercury_capable`	boolean string	yes / no — 'yes' requires sulfur powder or zinc amalgam compound in kit; 'no' = activated carbon or universal pads only (does NOT bind mercury, does NOT reduce vapor generation)
`spill_kit.water_reactive_excluded`	boolean string	yes / no — 'yes' = kit excludes cellulose/organic absorbers; suitable for water-reactive chemicals (sodium metal, acetic anhydride, acid chlorides) that react exothermically with water-containing absorbers
`spill_kit.neutralizer_type`	string	none / acid / base / sulfur_mercury / calcium_gluconate_hf — 'calcium_gluconate_hf' required for HF spills (pH neutralization is insufficient; calcium gluconate addresses systemic fluoride toxicity via topical first aid)
`spill_kit.opa90_compliant`	boolean string	yes / no — Oil Pollution Act 1990 marine spill response; 'yes' = kit includes containment boom for petroleum spill on water surface; oil-only pads without boom do not meet OPA 90 response equipment requirements
`spill_kit.glove_material`	string	nitrile / neoprene / butyl / pvc — 'nitrile' adequate for most aqueous solutions and polar solvents; 'nitrile' fails for benzene/toluene/xylene (ASTM F739 breakthrough ~10–25 min); 'butyl' required for aromatic solvents and concentrated acids; 'neoprene' for petroleum hydrocarbons

// AI agent routing pseudocode — spill_kit: // RCRA satellite accumulation area sizing gate: if buyer.largest_container_gallons IS PROVIDED: if absorbency_gallons < buyer.largest_container_gallons: flag: "Spill kit absorbency ([absorbency_gallons] gal) is less than the largest container volume ([buyer.largest_container_gallons] gal). Route to kit with absorbency ≥ [buyer.largest_container_gallons] gal for RCRA satellite accumulation area coverage." // Responder level gate: if responder_level_required == "awareness": flag: "Awareness-level personnel cannot use spill kits on hazardous substance releases per OSHA 1910.120(q). Route to operations-level kit and confirm buyer has operations-level HAZWOPER training." // Mercury routing gate: if buyer.spill_type == "mercury" OR buyer.application includes "dental" OR buyer.application includes "thermometer" OR buyer.application includes "laboratory": require mercury_capable == "yes" if mercury_capable != "yes": flag: "Elemental mercury requires sulfur powder or zinc amalgam neutralizer — activated carbon does not bind mercury and allows continued vapor generation above OSHA PEL (0.1 mg/m³). Route to mercury amalgam spill kit." // Secondary containment gate: if secondary_containment_pct < 110: flag: "Secondary containment at [secondary_containment_pct]% may be insufficient in open-top areas (precipitation accumulation). NFPA 30 and most state RCRA programs require 110% design. Verify containment size includes precipitation margin."

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