This position paper addresses open bermed containment systems at commercial retail fuel facilities that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c), and replaces ASTSWMO’s July 2016 position on these systems. The new document clarifies that ASTSWMO’s position addresses open bermed containment systems at retail fueling facilities, includes additional details about the construction and design of spill buckets vs open bermed containment systems, and new and updated references and resources.