Employers Cautioned to Consider Hazards Posed by Hand Sanitizer & Cleaning Products
by Betsey Kulakowski, CSHO, COSS
Executive Director, Oklahoma Safety Council
In the Age of COVID-19, employers are arming themselves with as many lines of defense as possible. Frequent housekeeping and alcohol-based hand-sanitizers and household cleaning supplies are all important weapons in the spread against infection. But as businesses begin to return to something akin to “normal”, having those products available is essential, but finding those products we rely on every day has become a real challenge.
Just go to Amazon and look up Lysol. Sure, you will find lots of links, but you will be hard-pressed to find anyone who has it in-stock – or anything like it. You probably will not have much luck finding Purell hand-sanitizer either. What you will find are alcohol-based hand rubs that are liquid and made – who-knows-where. Lately, a surge of ethyl-alcohol based hand rubs are becoming a more likely substitute too.
The reason for the shortage is a disruption in the global supply chain. Chemical manufacturers struggle to get the raw materials – most of which come from China – needed to make such products. Those who can get them are having a hard time keeping up with the demand, and most are going to the health-care industry where the need is greatest.
The liquor industry is helping, pitching in by creating hand rubs from what might have become a beverage at some point in its life cycle. But there are issues with these products as well. The Alcohol and Tobacco Tax and Trade Bureau waved the specific laws that allow distilled spirit makers to produce hand sanitizers. These substances are not meant to be consumed and they smell or taste bad enough to make them unpalatable. But they still contain a very high alcohol content – government officials are recommending at least 60% alcohol in order to be effective against COVID-19 – unfortunately, these can pose a fire hazard when used improperly.
While the Food and Drug Administration has issued guidelines permitting these products to be prepared and distributed, OSHA has not issued any changes to the Hazard Communications or Flammable Liquids standards. Employers who opt to use these products must still apply the OSHA requirements to their workplace, including obtaining a safety data sheet (SDS), including the product on their chemical inventory list, and training employees on the hazards of the chemicals before they are exposed to them. Additionally, flammable liquids must be stored and used in approved containers which are properly labeled in accordance with the labeling requirements of 29 CFR 1910.1200.
Isopropyl alcohol is highly flammable and can ignite very easily. Another risk is poisoning. IPA poisoning occurs when the liver is no longer able to manage the amount of IPA in the body. Hand sanitizer, in general, may be used safely, however, at large quantities or on soft skin (like a child’s), it can enter the body and cause significant damage.
In at least one case reported in early May of 2020, a worker was seriously burned while using alcohol-based hand sanitizer for COVID-19 personal hygiene. The worker had applied the gel-based product but did not allow it to dry before he touched a metal surface where a build-up of static electricity ignited. The resulting flame was almost invisible. The worker was able to extinguish the flames but was left with first and second-degree burns on his hands.
In the interest of safety, its important that employers and employees recognize the potential hazards and implement best-practices to avoid them. Employees need to be trained to know that the vapors can ignite whenever there is a potential ignition source, such as light switches, static, or cigarettes.
Fire Prevention Plans must also address storage and use of flammable liquids and must include no smoking (and no arc or spark potential) policies in areas where flammable liquids are stored and used. Keep in mind that only approved containers may be used for flammable liquids, so transferring to other bottles may pose a risk of fire hazard, particularly where containers are not bonded/grounded, or may produce static or spark that could ignite the liquid. Storage quantities are also limited by the OSHA Standards in 29 CFR 1910.106.
Can we make our own hand sanitizer? Well, it is still a free country, but keep in mind, when you make a chemical, you become the manufacturer and there is a section of the hazard communication standard that covers chemical manufacturers. It puts the burden on the employer to conduct the hazard determination and create the safety data sheet for the product.
The real question is: Should you make your own hand sanitizer? These products are regulated as over the counter (nonprescription drugs) by the US Food and Drug Administration. The FDA does not recommend that consumers make their own. If made incorrectly, hand sanitizer could be ineffective – or worse. There have been reports of skin burns from homemade hand sanitizer. Also, adding alcohol to non-alcohol hand sanitizer is unlikely to result in an effective product.
So, what options do we have? If you have a sink in your facility, keep in mind, soap and water is always the preferred method of reducing the spread of the COVID-19 virus. When soap and water is not available, hand sanitizer is appropriate. Hand sanitizer was intended to be the exception, rather than the rule, for times when it was not possible or practical to wash your hands.
Cleaning products are also an important step in preventing the spread of COVID-19, but too many people think if “some is good, more is better”. That is not always true. I heard someone on the radio say that “bleach and Lysol were the perfume of the COVID outbreak”, and while that is not too far from wrong, we need to take a step back and be reasonable.
Bleach, probably the most commonly available at the moment, is an acceptable disinfectant for surface cleaning in most cases. It is specifically mentioned in the bloodborne pathogens standards. But bleach has to be diluted to be used safely. 10-parts water to 1-part bleach is ideal. Here is the other thing to remember. It has to be mixed fresh and used within 24 hours in order to be fully effective. It also has to be stored in a properly labeled container that complies with the labeling requirements of the hazard communications standards.
Bleach, however, should never be mixed with ammonia, rubbing alcohol, vinegar, baking soda, or other alkaline and acidic chemicals. Bleach and ammonia are common ingredients in commercially prepared cleaners, so mixing chemical products must be done with extreme caution. Again, this is where the safety data sheet for products in your workplace can be a real life-saver – literally.
Bleach and alcohol are used to make chloroform. When Lysol and bleach are mixed, the bleach oxidizes the 2-benzyl-4 chlorophenol that is in the Lysol. The results are various irritating and toxic compounds.
In addition to engineering controls, administrative controls, and safe work practices, personal protective equipment may also be needed for using cleaning products.
Not all personal protective equipment (PPE) is created equal. The Safety Data Sheet (or product label) will identify the type of protective equipment needed for the job and the appropriate PPE should be selected.
Remember, PPE is your last line of defense, and the most likely to fail. Always follow the hierarchy of protection when deciding how to address hazards. Elimination/Substitution, Engineering Controls, Administrative Controls/Safe Work Practices should always be considered (and implemented where feasible) before skipping straight to protective equipment. PPE, however, may still be needed in conjunction with other controls.
Be sure to conduct your hazard assessment for all non-routine tasks and document the required protective equipment. Make sure workers are trained, not only on the PPE they need but on the limitations of their PPE, how to properly don and doff, how to clean and store, as well as when to discard and replace.
For additional information on OSHA’s hazardous communications standard requirements (GHS), can be found here: https://www.osha.gov/dsg/hazcom/otherresources.html
You can also find more on fire prevention and fire safety here: https://www.osha.gov/SLTC/firesafety/
For more information on personal protective equipment, go to: https://www.osha.gov/SLTC/personalprotectiveequipment/index.html