Data Center EHS&S Gaps: What the Industry Isn't Talking About

The EHS&S Gaps the Data Center Industry Isn't Talking About

Article 1 of 4 in the series: The Full Lifecycle of EHS&S in Data Center Development

If you had told me years ago — as a first-generation college graduate studying nursing systems and English — that I would be writing about data center cooling systems, generator emissions permitting, and water use effectiveness metrics, I might have paused.

But my career has always centered on one principle: how systems impact people. And right now, few systems are reshaping American communities as rapidly as data center development.

I see it every day in the Carolinas, where I live and work.

What I'm Seeing in My Own Backyard: Data Center Growth in the Carolinas

In York County, just outside Charlotte, QTS continues expanding its data center campus — reinforcing the Southeast's role in hyperscale and AI infrastructure. In Spartanburg County, local officials recently approved the second reading of a tax incentive package for TigerDC's proposed $3 billion AI-focused campus, Project Spero, with the first phase expected to deliver 100MW and incorporate closed-loop cooling.

These aren't abstractions for me. These are projects unfolding in the communities where I raise my family, where I volunteer, where I serve on boards. The land use decisions, the water demand, the construction activity, the air quality implications — I experience these as a neighbor, not just a consultant.

That proximity is also what makes me proud of what South Carolina is doing legislatively. The recently introduced Data Center Development Act (S.867) and Data Center Siting Act (S.902) go beyond tax incentives. They establish a structured governance framework that includes formal siting certification, infrastructure adequacy assessments, environmental impact review, measurable WUE-based water efficiency standards, noise and vibration mitigation requirements, decommissioning plans, and ongoing compliance reporting.

This isn't about slowing growth. It's about creating predictability, protecting ratepayers, conserving water resources, and aligning infrastructure expansion with long-term environmental stewardship.

Why I Attended a Data Center Cooling Conference

In February, I spent two days at the Advancing Data Center Cooling Innovation conference — a forum dedicated to the evolving role of mechanical engineering in next-generation data centers. The speakers were from Microsoft, AWS, Equinix, NTT Global Data Centers, JLL, Arcadis, and a dozen other firms at the forefront of this infrastructure shift.

I went because the engineering decisions being made in rooms like that one — decisions about cooling systems, water consumption, power density, and equipment layout — have direct environmental, health, and safety consequences. And I wanted to understand those decisions from the engineers making them.

What I found was extraordinary technical depth — and a significant gap. Data center EHS&S — the integration of environmental permitting, worker safety, and long-term compliance into the infrastructure decisions being made right now — wasn't on the agenda.

That gap is exactly why I was there.

The EHS&S Gaps in Data Center Design

The transition from air cooling to liquid cooling doesn't just change the thermal profile of a facility. It introduces new coolant chemicals that require hazardous materials management. It creates CDU maintenance environments that may qualify as confined spaces. It changes the piping system hazard profile in ways that traditional data center safety programs weren't designed to address.

Water use effectiveness isn't just a mechanical design KPI. When an engineer chooses between air-cooled, adiabatic, and hybrid adiabatic systems, that choice directly determines water withdrawal permit requirements, discharge permitting obligations, and compliance with emerging state-level water efficiency standards.

Scaling generator fleets to support AI-ready power densities isn't just an electrical engineering challenge. A large data center campus with 50 to 200 diesel backup generators represents an emission source comparable to a small power plant. As campuses scale, many are crossing the threshold from minor source to major source classification under the Clean Air Act — triggering Title V permitting and significantly more complex compliance obligations.

The commissioning phase — the transition from construction to live systems — was referenced throughout the conference. But the safety implications of commissioning are profound. You're energizing massive electrical systems while construction may still be active in adjacent areas. Arc flash hazard analysis, lockout/tagout coordination between construction and commissioning zones, and phase-specific safety plans are not optional considerations. They're life-safety requirements.

Where EHS&S Strategy Belongs in Data Center Development

Data center development is not simply about power density or cooling efficiency. It's about building resilient infrastructure that protects people, communities, and natural resources.

At Citadel EHS, we support data center projects from site selection through operations — integrating environmental engineering, industrial hygiene, safety consulting, permitting strategy, and sustainability planning.

What's Next in This Series

This is the first article in a four-part series exploring the full lifecycle of EHS&S in data center development:

Article 2 — Construction and commissioning safety: the highest-risk phases that most EHS&S programs don't specifically address — including how the liquid cooling transition changes the safety profile

Article 3 — Environmental permitting and water stewardship: how engineering decisions cascade into regulatory obligations, and what emerging state frameworks mean for compliance

Article 4 — The hidden liabilities: PFAS in fire suppression, battery storage safety, and what happens when your generator campus crosses the Title V threshold

Data centers power the digital economy. How we develop them will define our environmental legacy.