With the push to return to work after the COVID-19 epidemic there is a lot of talk about cleaning and disinfection. As important as it is to clean and disinfect the workplace, it is also imperative that employers make their employees aware of the new cleaning chemicals being used in the workplace.
Cleaning and disinfection requires cleaning chemicals, some of them new to a particular workplace. Anytime a new chemical is introduced into the workplace it should be done in accordance with OSHA HAZCOM (or Hazard Communication) rules.
What is OSHA HAZCOM (Hazard Communication) rules?
Hazard Communication rules are known as the “right to know” law. Meaning an employee has the right to know everything about a chemical he or she is exposed to and what steps are needed to protect themselves.
What to communicate OSHA HAZCOM rules with your Employees?
Fortunately, consumer products used in the workplace in such a way that the duration and frequency of use are the same as that of a consumer are not covered in the hazard communication program.
It is when use of those consumer products exceeds normal usage that an employer must adhere to HAZCOM rules. For an example, if an office worker uses a disinfecting wipe to clean their own workstation that would be normal use. But if that same worker used the product to clean 50 workstations a day, 5 days a week, they would have to be trained in how to safely use the product.
How to follow OSHA HAZCOM Rules?
Employers should keep complete transparency with their employees when using cleaning chemicals. There are two ways for employees to get safety information about the product; the product label, or the Safety Data Sheet (SDS), formerly known as the Material Safety Data Sheet (MSDS). Employers are required to have an SDS on file for any chemical that is used beyond what would be expected of a normal consumer.
Important information that can be found on the label or SDS include:
- A signal word
- Warning – less severe hazards
- Danger – more severe hazards
- What the hazards of the chemical are
- Physical – explosive, flammable, gas under pressure, etc.
- Health – acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard
- An image with a white background and red border giving employees a quick visual reference about what hazards may be present and how severe they may be.
- How to store the chemical
- What PPE to wear
- How to dispose of the chemical
- What first aid procedures might be needed for various accidents
As part of their workplace HAZCOM program, employers should ensure that employees know where safety data sheets (SDS) are maintained, how to use them and how they can be accessed. Online access to SDS’s is acceptable provided the employer can ensure employees are competent to access the information and adequate back-up is provided in the event of a power failure.
Below are some links to OSHA rules on chemical labels, Safety Data Sheets and pictograms.