
Proper use of chemicals is tantamount to safety. Scrupulously follow the directions for use, storage, and disposal of any chemical. It’s the responsibility of a business owner to both provide training and be certain that employees adhere to all expectations.
A business owner should devise a set of two or three questions as a self-check on whether a proper training program for chemicals is in place. Have the list appear as a calendar alert on a regular basis or at random intervals.
Linda Chambers, the brand and sales manager at GCE/Soap Warehouse in Norcross, GA, says she would include three questions: “Does every employee know where the SDS binder(s) are kept and that there is an SDS [safety data sheet] for every chemical used and stored on property and transported?
Second, “Does every employee know what to do in case of a chemical emergency or chemical spill?” continues Chambers; and third, “Does every employee read and understand all chemical labels, pictograms, and SDSs?”
Understanding is very important. If there are employees who are not native speakers of English, instructions and training must be provided to them in their native language.
Frequency and timing of training are equally important. A business owner should consider how often training should be given, says Chambers.
“First, train every new employee at hire and prior to starting work,” explains Chambers. “Then once yearly for refreshers and to go over any new updates or changes.”
And as with any safety protocol, instruction in proper use of chemicals should also be given on an as-needed basis. If any lapse in proper procedure is observed by an employer, it must be addressed immediately.
Contractors on the move must carry SDSs for each chemical they transport. Carry them and be certain of their location.
“SDSs should be located anywhere on the truck that there is a designated location of paperwork,” says Mike Dingler, owner of Firehouse Power Washing in Peachtree City, GA. “This paperwork must be readily available if there were a chemical spill due to a motor vehicle collision, etc.”
Essential training for employees begins with the SDS, says Dingler. It also includes “procedures for chemical handling, use, storage, and disposal.”
And although not every employee is expected to be versed in chemistry, every employee is expected to understand the defining characteristics of the chemicals he or she uses, explains Dingler.
For instance? “What is the pH of your chemicals, and do you know which ones should never be mixed together?” says Dingler. For example, acids and bases may mix violently (exothermically), posing a danger.
But assume there’s not much general knowledge and instruct employees in the fundamentals. The more employees understand, the better choices they will make.
“Most chemicals used in exterior cleaning can be handled with basic PPE [personal protective equipment] such as gloves and safety glasses,” says Dingler. But it’s knowledge that informs the type of PPE, and employees who understand that—as part of their training—will always check.
Chambers’ company is a distributor and supplier of equipment and chemicals as well as the creator of the Soap Warehouse Brand. Dingler’s company falls into the contract cleaner category.
Distributors, contractors, and manufacturers must train employees in chemical use. Of course, companies falling into each category have a different vantage. (Yes, whichever view a business has, the expectations and requirements for training converge.)
But let’s be sure to include advice from a manufacturer. Dave Peterson is product manager/Northwest regional sales representative at Alkota Cleaning Systems Inc. in Alcester, SD. He responds to our queries on behalf of Jeff Burros, vice president of sales at the same company, who prepared a handy trio of questions that can be used as a self-test for employers. We include that text as a sidebar.
In this section we look at the standards established by OSHA and the training required to ensure they are met.
As members of our industry know, it’s not possible to retrieve from OSHA a list of applicable standards specific to members of our industry in any category, whether contractor, distributor, or manufacturer. This is one of the reasons professional organizations such as CETA, PWNA, and UAMCC work diligently to keep members informed of expectations as well as changes in expectations.
Hazard Communications, standard number 1910.1200, is one framework that applies to our industry. Hazardous Materials, standard number 1910.107 subpart H, is another. The latter encompasses PPE.
We will summarize some of what’s expected regarding training, but the place to begin is here: An employer is required to provide a safe workplace. OSHA exists to ensure employers do that.
Training employees is part of establishing a safe workplace. OSHA specifies which training employers must provide, but it leaves how to train to the discretion of the employers.
In the realm of chemicals, employees must be trained to know the hazards of chemicals they use, how to safely store chemicals, how to perform mixing and dilution, when to use PPE (and how to use it), what to do in an emergency, and how to access SDSs. Take the list of what employees must know, and that’s the outline for training (and retraining).
An integral part of OSHA’s safe workplace focus is the environment in which employees work. Employers must be sure that employees know how to recognize and respond to flaws in ventilation, missing labels, and so on.
Imagine an employee in a work setting such as loading/offloading chemicals on a dock at a manufacturing facility, compounding at a distributorship, or power washing on a jobsite. Then, think about what could go wrong.
What could happen will dictate what employees need to know. Whether a dropped box and spill on the loading dock, a mixing error while compounding, or an errant spray on a customer’s prize roses (or automobile), employees must be prepared to respond.
The correct response derives from proper training. Yet the how of the training is left to each employer. To emphasize the preceding point, here is an excerpt from OSHA 1910.1200(a)(2):
Classifying the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures.
To put it bluntly or matter-of-factly, the employer has the discretion, and OSHA has the authority. Note the “may include” and “but is not limited to” phrases, which remind us that expectations can increase.
Compliance with meeting OSHA requirements for maintaining a safe workplace depends upon proper training of employees in the use of chemicals. No business owner wants to expect the worst, but being prepared for the worst—that spill or errant spray or yet-to-be-determined—is a must.
There are private companies across the country that will assist employers with training in chemical use. Even so, one of the best places to begin when seeking help is with a professional organization because organizations such as those already mentioned tailor training to the specifics of the industry.
One final point to illustrate the complexity of compliance. In the OSHA lexicon, a “chemical means any substance or mixture of substances” (1910.1200(c)(iii)). Water is a chemical, and so is saltwater.
Training means being prepared (to the extent possible) for anything. In truth, there is no book to follow but rather just good guidance and good judgement. Each employer is writing the script while going along with the curves in the road.
*Offered by Alkota Cleaning Systems Dave Peterson on behalf of Jeff Burros.