Six Litres on the Asphalt
In February a technician loads two 10 L jugs of a pyrethroid emulsifying concentrate and a case of aerosol cans into the back of an unpartitioned van and drives to a job. On a residential street he brakes hard: one jug tips, the cap cracks, and roughly 6 L of concentrate spreads across the cargo floor and out the open rear door onto the asphalt, running in a thin film toward a curb inlet that discharges to a creek. It is -5 C. He has a broom, cardboard, a shovel from his kit and no spill kit. A passing resident's dog steps in the puddle and licks its paw.
1. Sequence the technician's actions for the first thirty minutes, with the reason for each step.
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Priority order is people → drain → source → waste, and it matters that he does not start at the puddle.
- Stop and secure. Park safely, hazard lights on, keep bystanders and the dog back. Do not drive off: movement spreads product and turns a small spill into a trail.
- PPE. Solvent-resistant/nitrile gloves, boots, eye protection; avoid breathing vapour; ventilate the cargo area by opening doors on the upwind side.
- Protect the inlet first. Lay cardboard, a mat or soil from a planter across the curb inlet and build a soil/sand berm at the leading edge of the film, working from the drain back toward the spill. Six litres reaching a storm drain means a fish kill downstream; this is the single highest-consequence action.
- Control the source. Right the jug, tape or cap the crack, and place the damaged jug inside a pail or the intact jug's packaging.
- Absorb, do not wash. Spread absorbent - soil, sand, kitty litter, dry cardboard - over the film, sweep it into a pile, then do a second pass with fresh material. No water and no snow: water spreads an emulsifiable concentrate, carries it to the drain, and at -5 C it freezes into a sheet you cannot pick up. Scrape the viscous film with the shovel and cardboard first, then absorb.
- Package and segregate. Seal the absorbent and contaminated cardboard in a labelled, lidded container, keep it out of the cab, and keep the area cordoned until it is clean.
2. What notification and disposal obligations apply, and to whom?
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Notification. A pesticide reaching the environment is a reportable spill under Ontario's Environmental Protection Act. He must notify the ministry's Spills Action Centre immediately, and the municipality, and tell his supervisor or licence holder, the vehicle owner and the property owner/occupant. Do not wait to see whether it rains or whether the creek 'looks fine' - the film was running toward a drain that discharges to a watercourse, which is exactly the situation the duty to report exists for. Record the time of the spill, the time of each call, the volume, the product name and PCP registration number, and the actions taken.
Disposal. The absorbed material, contaminated cardboard, gloves and the damaged jug are pesticide waste. They go into a labelled, sealed, puncture-resistant container and then to a licensed waste hauler or a household hazardous waste depot that accepts pesticides. Never the storm drain, the sanitary sewer, the garbage, a dumpster or the ground. Obtain and keep the disposal receipt; that receipt is the evidence the spill was closed out properly.
Follow-up. A written incident report to the employer, a review of whether the drain required municipal flushing or a creek inspection, and confirmation that the residue on the asphalt was wiped or absorbed rather than hosed away.
3. What should be done about the dog, and what changes would prevent a repeat?
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The dog. Do not attempt treatment. Keep the animal from grooming or licking, rinse the paws with soap and lukewarm water, and do not induce vomiting. Give the owner the product name, PCP number and SDS, and advise contacting a veterinarian promptly and mentioning a concentrated pyrethroid - dermal exposure to concentrate commonly causes tingling or numbness, and ingestion is more serious. Record the owner's name, contact and the time.
Prevention - the failures here were all preventable:
- A spill kit in every vehicle: absorbent, drain covers, a sealable pail, bags, labels, PPE, a torch.
- Secondary containment: liquid concentrates in lidded, secured bins, not loose in an unpartitioned van; aerosol cans segregated.
- Load restraint and pre-trip cap inspection - a cracked cap from a hard brake is a load-securing failure.
- Doors closed while moving.
- Driver training and a documented pre-trip check, plus a lone-worker procedure for reporting a spill.
- Housekeeping: a damaged jug should never have been loaded.
The unsecured, uncontained load is itself a compliance issue as well as a safety one, and it belongs in the incident report alongside the spill.