Spill Response

A spill or release is the unplanned discharge of a material to the ground, water, or air. It is advisable to have an emergency spill containment kit available that contains absorbent materials such as clay, pads, or socks to contain or minimize the affected area. A clean work site helps reduce trips, slips, and falls. Because B-side chemicals can be extremely slippery, mark and clean up spills, particularly from smooth walkways or floors, as soon as possible.

Although infrequent, sizable spills and releases of A- and B-side chemicals can occur. If this happens, it is important to take immediate action to minimize environmental contamination.

You may be required to report spills and releases of spray foam and coating ingredients to local, state, and/or federal authorities. For this reason, keep all containers of chemicals tightly sealed except when they are actually in use. In the event of a large A-side chemical spill or release (i.e., more than a few pounds or gallons), consider the following:

• Direct all personnel away from the immediate area to avoid unnecessary exposure.
• Provide appropriate PPE for individuals involved in the cleanup. PPE for cleanup crews may include appropriate respiratory protective devices, impervious clothing, footwear, eye protection, and gloves in accordance with OSHA regulations.
• Absorb the A-side chemicals with sand, wet earth or absorbent clays (e.g., vermiculite or cat litter). Place the absorbed material in drums and neutralize. Do not seal these drums for an appropriate period (typically, at least 48 hours).
• Check to see if you have exceeded the reportable quantity (RQ) (Reportable quantity for MDI is 5,000 lbs), which is the equivalent of approximately 15 drums of a typical A-side material. Note that 10 drums of A-side chemicals are a large quantity; a typical single family residence or commercial application is likely to have fewer drums present. Call the EPA’s Superfund Call Center 1-800-424-9346 or consult 40 CFR §302.4. If it is determined that you have exceeded this amount, you must report the spill to various government agencies.
• Characterize waste (e.g., hazardous or nonhazardous waste) and dispose of waste in accordance with all applicable regulations.

You may be required to report sizable MDI or solvent spills or releases to a Local Emergency Planning Committee (LEPC), State Emergency Response Commission (SERC), and the National Response Center (NRC). The penalties associated with not reporting are quite substantial, so it is better to be conservative.

Job site wastes consisting solely of construction debris, such as old roofing materials, do not normally require any special handling or packaging for disposal, unless they contain asbestos or other unusual hazardous materials. If you are unsure, it is suggested that they be treated as hazardous. However, cured polyurethane foam does not meet the criteria of a hazardous waste according to Resource Conservation and Recovery Act (RCRA), and should be acceptable for landfill disposal. Some landfill facilities may ask for a SDS on cured polyurethane foam before allowing disposal. It is suggested that the state and/or local waste disposal regulatory authority be consulted prior to disposal of any type of waste.