As states begin reopening, many facilities will need to rethink how to clean and disinfect the workplace to protect employees from COVID-19 and comply with State and Federal guidelines. However, these changes may require new or revised OSHA hazard communication strategies, depending on which cleaning/disinfecting agents are being used.
First, EPA makes a clear distinction
between cleaners, sanitizers, and disinfectants:
- Cleaners remove dirt through wiping, mopping, or scrubbing.
- Sanitizers contain chemicals that reduce, but do not necessarily eliminate, microorganisms, such as bacteria, viruses, and molds.
- Disinfectants contain chemicals that destroy or inactivate microorganisms that cause infections. EPA has compiled a list of disinfectants that can be used against COVID-19.
Cleaners, sanitizers, and disinfectants each serve a unique purpose, and it is important to always choose the least hazardous substance for the task at hand. In general, sanitizers and disinfectants are often more hazardous than cleaners and are more likely to be regulated under EPA standards. Therefore, facilities that use sanitizing/disinfecting agents are required to adhere to OSHA’s hazcom standards.
Overseeing the disinfecting process? Lion's Managing Hazard Communication online course prepares environmental and safety managers how to create and implement a workplace Hazard Communication Program as required by 29 CFR 1910.1200(e)(1).
Assessing Your Workplace
Determine what the frequently touched areas in the facility are. CDC recommends
looking indoors for hard, non-porous materials that are touched every six days or less. This may include doorknobs, tables, railings, shared PPE, handles, steering wheels, countertops, or control panels. These surfaces may require disinfecting.
Once you find which surfaces require disinfecting, create a plan for when and how to disinfect.
Make the plan as comprehensive as possible to include which areas are high and low priority, what disinfectant(s) are used, and how frequently each area is disinfected.
Check the Bottle
Check your cleaner, sanitizer, or disinfectant for a Safety Data Sheet (SDS). Hazcom regulations require employers to obtain and keep a record of SDSs for all hazardous cleaning chemicals they use.
An SDS is essential to ensuring all workers understand what these substances are and how to handle them safely. An SDS can even provide guidance for what protective measures may be required, such as recommended personal protective equipment (PPE), ventilation requirements, etc.
Remember, no two cleaning agents are the same. Carefully assess each chemical or cleaning product used to determine what specific usage requirements, PPE, and/or training may be needed.
HazCom Training Made Simple
OSHA requires hazcom training for anyone who uses or comes into close contact with regulated hazardous chemicals and cleaning agents [29 CFR 1910.1200(h)]. Lion’s online Hazard Communication course
makes it easy for workers to understand their responsibilities and learn how to safely use these products.
Workers who complete this course can recognize and use hazard labels and Safety Data Sheets to protect themselves and their co-workers from chemical hazards on the job.