OSHA’s COVID-19 Tip of the Day (Tip #75)

Most manufacturing companies are aware of the need to develop a Hazardous Communication Program (per 29 CFR 1910.1200) if you use or manufacture hazardous chemicals at your facility. Specifically, do any of the chemicals you use in either your processes or in maintenance have a Safety Data Sheet (SDS)?  If so, you as the employer are responsible for conducting a hazardous chemical inventory and developing a list of all hazardous chemicals in the workplace by using the identity that is referenced on the SDS and the container label. This identity is often a common name, such as a product or trade name. The Hazard Communication Standard also requires that this list be specific to the workplace as a whole or for individual work areas. The rule also requires that you inform employees of the hazards through SDSs, labels, and training.

While you have been busy buying up all the Lysol Spray, Clorox Disinfectant Wipes or other disinfectants you can locate and developing the stricter cleaning processes that will keep your business in compliance with the COVID-19 guidelines, have you also remembered to add the new hazardous cleaning chemicals to your Hazardous Chemicals List and train your employees on how to use them safely? When was the last time you reviewed and updated that Hazardous Chemicals List for all the chemicals on-site? Don’t forget the “cleaning closet” as well as the maintenance shop.  If the chemical is stored there and has hazardous characteristics, it belongs on the list. Specific recommendations from OSHA on “Cleaning Chemicals and Your Health”, can be found here.

Conducting a comprehensive chemical inventory, developing a current Hazardous Chemicals List, completing a Written Hazard Communication Program, and assuring proper employee training can be daunting tasks!  If you have your well-washed and disinfected hands full just getting your business reopened and back to profitability, let CTI assist you in complying with the second most-frequently cited OSHA violation, the Hazard Communication Standard.

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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