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Environmental & Hazardous Materials Policy

Comprehensive guidelines for the safe introduction, handling, storage, and removal of hazardous materials within GridColo facilities to protect personnel, equipment, and the environment.

Version 1.0
September 5, 2025
1. Purpose and Objectives

This policy establishes the conditions under which environmental risks and hazardous materials are introduced, stored, handled, transported, used, and removed from GridColo facilities. Data centers incorporate sensitive electrical and mechanical infrastructure whose reliability depends on clean air, predictable thermal conditions, and strict contamination control.

Certain materials—flammables, corrosives, compressed gases, refrigerants, batteries, fuels, and industrial cleaners—pose disproportionate risks to life safety, continuity of operations, and regulatory compliance if unmanaged. The objective of this policy is to prevent incidents by ensuring that only appropriate substances are admitted to site, that quantities and methods are controlled, that incompatibilities are avoided, and that waste streams are handled in a lawful, traceable, and environmentally responsible manner.

2. Applicability

This policy applies to all non-GridSite personnel present at any GridColo location—customers, their agents, vendors, contractors, subcontractors, delivery teams, auditors, and escorted visitors—across all Security Levels. It covers materials and devices brought to docks, staging rooms, data halls, customer cages and cabinets, mechanical and electrical spaces, roofs and exterior plant areas, and onsite storage. It operates in parallel with the Safe Working Practices Policy, Contractor & Vendor Safety Policy, General Rules & Regulations Policy, and all posted site rules.

3. Policy Statement

No hazardous material may enter a GridColo facility without prior disclosure and explicit approval from GridColo Operations.

Approval is discretionary and may be conditioned on limits to quantity, location, time on site, packaging, secondary containment, ventilation, fire protection, supervision, and removal plans. Where a safer alternative exists, GridColo may require its use. All persons shall minimize environmental impact, prevent releases, and immediately report spills, leaks, or abnormal odors to GridColo. GridColo may halt work, quarantine materials, or require removal at any time if conditions deviate from approved controls or if risk is judged unacceptable.

4. Definitions and Material Classes

For the purposes of this policy, "hazardous materials" include, without limitation:

Flammable Materials
  • • Flammable and combustible liquids
  • • Flammable aerosols
  • • Fuels and lubricants
Chemical Hazards
  • • Corrosive liquids and solids
  • • Oxidizers and reactive chemicals
  • • Toxic or irritant substances
Compressed Gases
  • • Refrigerants, nitrogen, argon, helium
  • • Oxygen, CO₂, cryogenic fluids
Energy Storage
  • • Lithium-ion batteries
  • • Lead-acid batteries
  • • Industrial cleaners and solvents
5. Prohibited and Restricted Materials

Prohibited Materials

  • • Explosive, shock-sensitive, or pyrophoric materials
  • • Radioactive sources
  • • Uncontrolled open flames
  • • Bulk quantities of flammable liquids

Where small quantities are conditionally allowed—for example, limited aerosols for equipment cleaning or minimal solvent volumes for connector preparation—GridColo will specify the maximum container size, cumulative quantity, storage method, point-of-use restrictions, and time limits. Any material emitting persistent fumes, particulates, or sticky residues that could compromise filtration, sensors, or heat-exchange surfaces is not permitted in data halls.

6. Approval, Notification, and Documentation

Prior to mobilization, sponsors must submit a description of each material proposed for use or storage onsite, the SDS, intended task, quantity, duration on site, and disposal method. Where work orders are used, the hazardous material list shall be attached to the approved MOP/SOP.

GridColo will communicate conditions of approval—such as secondary containment, spill kits, ventilation or localized extraction, fire watch, and segregation—along with any exclusion zones. Materials arriving unannounced may be refused entry, returned to sender, or sequestered pending review.

7. Safety Data Sheets (SDS) and Labeling

An SDS must be readily available for each hazardous material present onsite, in English, current to the manufacturer's latest revision. All containers shall be labeled with the product name, hazard information, and responsible party. Decanted or working containers must carry secondary container labels that are legible and resistant to smearing. Illegible or unmarked containers are subject to immediate removal.

8. Quantity Limits and Time on Site

GridColo may set strict quantity caps for any approved material and will generally require "bring-in/bring-out" practices—small, task-sized quantities mobilized at the start of work and removed upon completion the same day. Bulk storage is discouraged; long-term storage of hazardous materials within customer cages, common spaces, or raised-floor areas is not permitted unless GridColo has designated a compliant storage cabinet and approved an inventory ceiling with cycle-count requirements.

9. Storage, Segregation, and Secondary Containment

All hazardous materials must be stored in closed, compatible containers and in locations specifically approved by GridColo. Incompatibles (e.g., oxidizers vs. organics, acids vs. bases, fuels vs. oxidizers) shall be segregated by distance and/or physical barriers per SDS guidance.

Where liquids are present, secondary containment sized to at least 110% of the largest container (or as otherwise specified by GridColo) is required. Storage shall never obstruct egress, airflow paths, sensors, or fire protection equipment.

10. Use in Data Halls and Critical Areas

Data halls, MMRs, and electrical rooms are "clean zones."

Only essential, pre-approved materials may enter, and only for the duration of active work. Aerosolized cleaners, solvent wipes, adhesives, and thread-lockers shall be low-VOC and used sparingly, with immediate capping and removal of wipes to closed containers. Open containers are not to be left unattended. Any activity producing odors or vapors detectable beyond the work area must cease and be re-planned with additional controls.

11-25. Additional Policy Sections

Compressed Gases & Cylinders

Proper handling, securing, and leak-checking procedures for all compressed gas systems.

Refrigerant Handling

Recovery, charging, and recordkeeping requirements for cooling system maintenance.

Fuels, Oils & Lubricants

Designated handling locations, spill control, and fire protection measures.

Batteries & Energy Storage

Lithium-ion and VRLA battery safety, thermal runaway prevention, and waste handling.

Cleaning & Maintenance Chemicals

Low-hazard product selection and proper dilution procedures.

Spill Prevention & Response

Prevention planning, spill kit requirements, and immediate response procedures.

Waste Management

Characterization, collection, and lawful removal of all waste streams.

Facility Transport

Safe movement protocols within buildings and designated transport routes.

Environmental Protection

Emission control, noise management, and stormwater protection measures.

Monitoring & Inspections

Regular inspection protocols and comprehensive record-keeping requirements.

Training & Competency

Required qualifications and specialized training for material handlers.

Incident Management

Immediate notification procedures and escalation protocols for all incidents.

Enforcement and Consequences

Non-compliance may result in immediate cessation of work, removal of materials from the building, suspension of credentials, cost recovery for cleanup or remediation, and, where appropriate, termination of colocation privileges. Willful or negligent violations that endanger life safety or the environment may be referred to authorities.