9.4 Hazardous Substances, Safety Data Sheets (SDS), Spill Response, and PPE

Hazardous Substances on Construction, Industrial, and MS4 Sites

Stormwater inspectors regularly inspect material storage yards, fueling areas, equipment maintenance pads, and chemical treatment skids containing hazardous substances:

• Petroleum Products and Lubricants: Diesel fuel, gasoline, hydraulic fluid, motor oil, cutting oils, and grease.
• Paving, Concrete, and Masonry Chemicals: Asphalt emulsions and tack coats, petroleum-based form-release oils, concrete curing compounds, epoxies, solvents, paints, and muriatic acid (hydrochloric acid used to etch concrete or clean masonry brick, which produces severely acidic runoff).
• High-pH Cementitious Materials: Uncured Portland cement, concrete washout water, stucco, mortar, and lime used for soil stabilization ($\text{pH } 11\text{ to }13$). In addition to polluting receiving waters, wet concrete and lime dust cause severe alkaline chemical burns to human skin and eyes.
• Stormwater Flocculants (Anionic vs. Cationic PAM): Polyacrylamide (PAM) flocculants are used on some sites to settle suspended clay particles. Use only the approved formulation and dose. Cationic treatment requires prior EPA approval under the CGP and may be prohibited or restricted by state/local rules in stormwater discharges because positively charged polymer chains bind tightly to the gill surfaces of fish and aquatic invertebrates, causing rapid mechanical suffocation and acute aquatic mortality at very low concentrations.

OSHA HazCom and the 16-Section Safety Data Sheet (SDS)

Under the OSHA Hazard Communication Standard (29 CFR 1910.1200 / 1926.59), harmonized with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), manufacturers must provide a standardized 16-Section Safety Data Sheet (SDS) (formerly known as an MSDS) for every hazardous chemical on site. Copies of all SDS documents (physical binder or immediately accessible electronic terminal) must be readily accessible to all workers and inspectors on site during every work shift.

When reviewing a chemical product or polymer proposed for use in a SWPPP, a CESSWI inspector must know where to look in the 16-section SDS:

Secondary Containment, SPCC Thresholds, and Inspector Spill Response

Secondary Containment and SPCC Rules

To prevent leaks or ruptured drums from reaching storm drains or soil, liquid chemicals and fuels stored on site must be placed inside impervious secondary containment (such as berms, dikes, or double-walled tanks/spill pallets) covered or managed to prevent rainwater accumulation:

• SPCC containment sizing: Sized containment for bulk storage must hold the entire capacity of the largest single container plus sufficient freeboard for precipitation under 40 CFR 112.8(c)(2). Federal SPCC does not impose a universal 110% figure or the hazardous-waste 10%-aggregate formula. A project detail may specify 110%, but verify design rainfall and usable containment volume after displacement.
• Federal SPCC Plan Thresholds (40 CFR Part 112): Under the EPA Spill Prevention, Control, and Countermeasure (SPCC) rule, any facility or construction site that could reasonably discharge oil into navigable waters or adjoining shorelines must prepare and implement a certified SPCC Plan if it has:
  • Total aboveground oil storage capacity $> 1,320\text{ gallons}$ (counting only containers with a capacity of $55\text{ gallons}$ or greater), OR
  • Total completely buried underground oil storage capacity $> 42,000\text{ gallons}$.

Inspector Spill Response Protocol: Caution, Notify/Control, Document

If a CESSWI inspector discovers an active fuel leak, ruptured hydraulic hose, or unknown chemical spill during an inspection:

1. Protect Your Own Safety First (Upwind and Upslope): Approach any suspected hazardous release from upwind and upslope (upgradient). Never walk through, touch, taste, or intentionally smell an unknown liquid or vapor. Unless you are specifically trained (e.g., OSHA 40-Hour HAZWOPER), medically cleared, and wearing chemical-specific PPE for that material, do not attempt hands-on cleanup of a hazardous substance release yourself.
2. Notify Immediately and Prioritize Source/Drain Control: Immediately alert the Site Superintendent or Emergency Coordinator so trained site crews can stop the source (shut a valve, upright a leaking drum) and deploy on-site spill kits (hydrophobic oil-only absorbent booms, pads, socks, granular clay/kitty litter, and neoprene storm drain inlet covers) to block the spill from entering storm drain inlets, ditches, or surface waters. Never allow crews to hose down a fuel or chemical spill with water or apply dish soap/emulsifiers, which washes the pollutant directly into the storm sewer.
3. Verify Mandatory Regulatory Reporting (NRC 1-800-424-8802):
   • Under the Clean Water Act "Sheen Rule" (40 CFR Part 110), if an oil or petroleum discharge reaches a Water of the United States or adjoining shoreline in a quantity that causes a film or sheen upon or discoloration of the surface of the water (or a sludge/emulsion beneath the surface), OR if a hazardous substance spill equals or exceeds its CERCLA Reportable Quantity (RQ) within a $24\text{-hour}$ period, the operator must immediately notify the federal National Response Center (NRC) at 1-800-424-8802 as well as required state/MS4 emergency agencies.
   • Under the EPA CGP, the operator must also document the release, complete a Corrective Action, and modify the SWPPP within $7\text{ calendar days}$ of knowledge of the reportable release.

The Hierarchy of Controls and Personal Protective Equipment (PPE)

According to NIOSH and OSHA safety principles, workplace hazards are managed using the Hierarchy of Controls, ranked from most effective to least effective:

1. Elimination (Most Effective): Physically remove the hazard (e.g., inspect an underground vault from the surface with a pole camera instead of entering it).
2. Substitution: Replace a hazardous material with a safer alternative (e.g., replace toxic cationic PAM or petroleum form-release oil with biodegradable vegetable-based release agents).
3. Engineering Controls: Isolate people from the hazard through physical design (e.g., trench boxes, secondary containment berms, equipment backup cameras/alarms, mechanical ventilation).
4. Administrative Controls: Change the way people work through procedures, schedules, training, warning signs, and heat-acclimatization rest breaks.
5. Personal Protective Equipment — PPE (Least Effective / Last Line of Defense): Protects the individual worker only if worn and maintained properly when higher-level controls cannot fully eliminate the risk.

Essential Inspector PPE Standards

Before stepping onto an active site, check the general contractor's site-specific safety plan and verify that your PPE meets minimum consensus standards:

• Head Protection: Hard hat or safety helmet meeting ANSI/ISEA Z89.1 (Type I protects against top impact; Type II protects against both top and lateral/side impacts; Class E is electrical-rated to $20,000\text{ V}$, Class G to $2,200\text{ V}$, and Class C is conductive with no electrical protection). Inspect the suspension liner regularly and replace shells damaged by UV chalking, cracks, or impacts.
• Eye and Face Protection: Impact-resistant safety glasses with side shields (or chemical splash goggles when sampling acid/caustic washouts) stamped ANSI/ISEA Z87.1 (Z87+ for high-velocity impact).
• High-Visibility Safety Apparel: Retroreflective vest or outerwear meeting ANSI/ISEA 107: select Type and Performance Class for the applicable traffic-control standard, employer hazard assessment, visibility, and work assignment; speed alone does not impose a universal federal Class 3 requirement.
• Foot Protection: Protective-toe (steel or composite toe) work boots with puncture-resistant soles and ankle support meeting ASTM F2413.
• Hand, Hearing, and Water Safety PPE: Heavy leather gloves for rough wire/stakes; waterproof nitrile or neoprene gloves when handling water samples or chemical containers; earplugs or earmuffs when noise levels exceed $85\text{ dBA}$ (8-hour action level) or $90\text{ dBA}$ (OSHA construction PEL); and a U.S. Coast Guard-approved Personal Flotation Device (PFD) when working on barges, steep rip-rap riverbanks, or deep retention pond outlet structures.

SPCC sizing and chemical-treatment qualification

SPCC bulk-storage containment requires the largest container’s entire capacity plus sufficient precipitation freeboard. A 110% project specification is an example, not a universal federal formula. Oil storage thresholds also require a reasonable expectation of discharge to navigable waters or adjoining shorelines and consideration of the rule’s exclusions. The CGP requires EPA approval before cationic treatment under Part 1.1.9; anionic PAM is not automatically safe or authorized. Verify formulation, residual monomer, dose, aquatic toxicity, site soils, approved treatment plan, and receiving-water restrictions before use. SDS Sections 12–15 retain standardized headings, but OSHA does not enforce their substantive content; lack of ecological data is not proof that a product is safe.