Preparation and Self-Certification of SPCC Plans
The Missouri Board has concluded that preparation and self-certification of SPCC Plans are engineering responsibilities and therefore are required to be prepared by licensed PEs. A public body, such as the United States Environmental Protection Agency may have a more stringent requirement than Chapter 327, RSMo; however, nothing in Chapter 327 permits a body to substitute a requirement which nullifies the requirements of Chapter 327.
It is the opinion of the Missouri Board that all plans that are Tier I or II have to be sealed and that any plans created in Missouri, other than by federal employees on federal lands, need to be sealed by a Missouri PE. However, the federal government has often disagreed with that interpretation and may apply different standards to its employees than to others.