Q&A: Do basic cleaning supplies belong in a HazCom plan?
How do I determine if basic cleaning supplies are considered hazardous chemicals and need to be included in a hazard communication plan?
Under federal OSHA’s hazard communication standard, if employees use a consumer product (such as a cleaning product) in the workplace in a manner, frequency, and duration of exposure that does not exceed the range of exposures a consumer would reasonably experience while using the product as intended, it falls under the hazard communication standard’s consumer products exemption at 29 CFR 1910.1200(b)(6)(ix), and you would not need to include it in your hazard communication program.
If the cleaning supplies used by your janitorial staff are the same products that are available to consumers, it is your responsibility as an employer to assess whether your employees’ use of those chemicals (i.e., the manner, frequency, and duration of use) is comparable to typical consumer use. However, if your employees’ exposure to these chemicals is significantly greater than what would occur during typical consumer use, you would be required to list these chemicals on your hazardous chemical inventory and maintain safety data sheets (SDSs), labels, training, and other required elements of the hazard communication standard for these chemicals.
Generally speaking, if a chemical product has an SDS, it has already been classified as hazardous by the manufacturer or importer of the chemical. It is the manufacturer’s or importer’s responsibility to prepare or obtain SDSs for all hazardous chemicals they produce or import. The hazard communication standard specifies criteria for the evaluation and classification of chemical hazards for the purpose of preparing SDSs.
As an employer or end user of a chemical product, your responsibility is to have an SDS for each hazardous chemical in use at your facility and make SDSs available to employees, ensure that hazardous chemicals in your workplace are properly labeled in compliance with the hazard communication standard, develop a written hazard communication program and make it available to employees on request, train employees on the chemical hazards they could encounter in the workplace, and provide any necessary protective equipment or other safety measures for employees exposed to chemical hazards.
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