Lessons Learned: Improving HazCom and Avoiding the Dangers of Incompatible Chemicals
by Phil Molé
An employee at a popular chain restaurant recently died due to chemical exposures from a reaction between common, but incompatible, cleaning compounds. This incident, like many others before it, is disturbing because the chemicals used are so common, and tragic because it is avoidable. It’s an unfortunate reminder that HazCom management is not just a regulatory obligation – it can literally be a matter of life and death.
In what follows, we’ll take a look at what is known about the incident, and draw some lessons about how to avoid similar accidents by improving our HazCom management.
The incident occurred on November 7 when an employee at a restaurant in Burlington, Massachusetts began cleaning floors with a commercially sold cleaner called Super 8, which contains sodium hypochlorite. The worker had not known that the floor was coated with cleaning solution remnants from an earlier spill of a second cleaning product called Scale Kleen, which contains acid.
Neither of these individual products are dangerous if used as directed while following proper safety precautions. However, the mixture of the two chemicals produced a substance that “turned green and started to bubble,” according to one news account, and the employee left the area due to symptoms of burning eyes and breathing problems. When the store manager then tried to clean up the mixture, he was overcome by fumes and later died at a local hospital.
Thirteen others were also hospitalized due to exposure to the fumes, according to the Burlington, Massachusetts Fire Department.
The reaction between hypochlorite and acid is an acid-base reaction, which produces chlorine and other toxic gases. Tragic incidents such as the one that occurred November 7 captures news headlines and builds awareness, to a degree, about the real dangers that chemicals in the workplace can pose but we need to be careful about the lessons learned, and not fall into the trap of thinking accidents like this can only happen “somewhere else,” to people who work with different kinds of chemicals than you have.
The truth is that chemical products like the one in this incident are very common. Commercially sold chlorine bleach is a solution of hypochlorite and water, and is found in many facilities and many homes, along with other cleaning products that contain acids. That means that incidents like this one are not particular to restaurants or to any other segment of industry. They can happen pretty much anywhere. And acid-base reactions are hardly the only kinds of reactions possible between incompatible chemicals possible. Reactions between strong oxidizers and strong reducing agents can result in potentially deadly explosions, as just one example.
The best way to honor a tragedy is to learn from it, and to do everything possible to prevent it from reoccurring. Let’s take a moment to draw some deeper lessons from this accident to improve our HazCom management.
Know Your Inventory
One of the first conclusions we should reach is that we need to know our chemical inventory. Most people already understand this at some level – they know that OSHA’s HazCom Standard requires them to maintain a current list of all hazardous chemicals in their workplace, and many times they stop there. The trouble is, as this restaurant incident shows us, we need to do more than that. We need to understand our inventory, including knowing what hazardous ingredients are lurking within the products used and stored in our workplace.
Remember, the names of the chemicals involved in this accident (Scale Kleen and Super 8) tell us nothing about what ingredients are contained within the products. Even if we understood the chemistry of acid-base reactions, we might not realize we have a potential problem until we are aware that these chemicals contain acid and sodium hypochlorite, respectively.
Many chemical products, including those widely available commercially, contain chemicals that have special regulatory, safety, or environmental considerations. For example, during the time I was a regulatory consultant, I found many examples of commercially sold aerosol cans of degreasing spray that contained methylene chloride, a toxic solvent covered by a specific OSHA standard that requires exposure assessments and medical surveillance if certain airborne concentrations are reached. Many employers who had these solvents were not in compliance with these requirements and were putting their employees at risk, because they didn’t realize they even had methylene chloride in their facilities.
How well do you know your inventory at the ingredient level? Having a higher level of visibility into what I call your real chemical inventory, meaning the one hiding behind sometimes innocuous sounding product names, is an important part of getting HazCom right.
Have SDSs for All Hazardous Chemicals
This is a corollary to the points about chemical inventories above, and similar nuances apply. Most employers know quite well that they’re required to have SDSs for all hazardous chemicals, although some often are unclear about what chemicals trigger the requirement to maintain SDSs.
The kinds of chemicals involved in the recent restaurant accident tend to trigger this kind of confusion. The HazCom Standard contains an exemption for consumer products in 29 CFR 1910.1200 (b)(6)(ix) if they are used “in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers” when they use the product for its manufactured purpose. Employers may sometimes know that there is an exemption for consumer products, but don’t always understand how the “duration and frequency” part of the equation may nullify that exemption, causing the product to be covered under the HazCom Standard and therefore requiring an SDS.
To determine whether or not a chemical product requires an SDS, an employer needs to carefully review how they are using the chemical in the workplace. Luckily, OSHA provides some guidance here in letters of interpretation (LOIs). For example, in a 2005 LOI, a stakeholder asked OSHA if the consumer exemption applied if employees regularly used commercially sold art chemical products such as paints and thinners to create visual aids and presentation displays. OSHA responded that although these were consumer products, if employee job duties caused them to be routinely exposed to hazardous chemicals, they would be using them at a duration and frequency greater than typical consumer usage and the workers would therefore need chemical hazard information available through SDSs and HazCom training.
We could draw an analogy here to cleaning chemicals. The average consumer who buys these products uses them pretty infrequently – storing them in a cabinet until there happens to be a spill to clean up. But if an employee has regular job duties that involve use of these chemicals, he or she would be exposed at greater duration and frequency than a consumer, and would need access to HazCom information including the SDSs.
If you’re looking for more information, please review our fact sheet “Does This Product Require a Safety Data Sheet?” And remember, when in doubt, err on the side of caution.
Use HazCom Information to Inform Storage and Handling Practices
Many employers care about safety, and generally meet their HazCom requirements, but don’t actually use the chemical hazard information to inform their storage and usage practices. The recent restaurant chemical accident shows us it is dismayingly easy for employers and workers to unintentionally use and store chemicals in dangerous ways.
I’ve personally seen this happen. In my consulting days, I once conducted an inspection of a facility where the EHS Manager had done a good job keeping their chemical inventory and SDS library up to date, making sure containers were labeled, and checking the boxes on other HazCom requirements. But when I entered the chemical storage room, I was shocked to find 55-gallon drums of sodium hydroxide stacked directly on top of drums of sulfuric acid. Strong acids and strong bases react violently, and if there had been any integrity issues with those drums or spilled material, the results could have been disastrous.
Be sure to pay close attention to Section 7 of the SDS and use that information to inform your chemical storage practices. Remember, certain chemicals are incompatible with others because they react strongly, such as acids and bases (like those in our example above), or oxidizers and reducers. There are also chemicals such as pure potassium metal, or lithium aluminum hydride, that react violently with water, and should not be stored anywhere close to a sink or other water source. Other chemicals may become unstable at higher temperatures.
Obviously, you’ll need to know these details about the chemicals in your own inventory, and plan your storage practices accordingly.
Sharpen Your Emergency Planning and Response
Think of chemical emergency planning as the practice of planning to avoid “unplanned incidents” involving chemicals such as fires or spills, and preparing to respond as quickly and safely as we can to the incidents that occur in spite of our preparation. Safe storage practices, as discussed earlier, help to prevent incidents from happening in the first place, but we have many other emergency planning obligations for which the information found on the SDSs and shipped labels will be helpful.
For instance, it is critical that you know the amounts of chemicals (or sometimes even the amount of certain ingredients within chemicals) stored on-site. This helps with effective emergency planning, and can be part of your regulatory obligations with EPA’s Emergency Planning and Community Right to Know Act (EPCRA).
For facilities with chemicals stored above their threshold limit, which is 10,000 pounds for most chemicals but significantly lower for chemicals listed as extremely hazardous substances (EHSs), compliance with EPCRA includes providing your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department with SDSs or lists of chemicals grouped by hazard categories. You may also need to complete and submit Tier II chemical inventory reports to the same parties, for those chemicals, by March 1 of each year.
On a more basic level, it’s your business to really know the pictograms and hazard classifications (including hazard statements and precautionary statements) for your chemicals. They are a primary source of information about your chemicals’ health and physical hazards. For example, a chemical classified as “Eye Damage Category 1” will have the hazard statement “causes serious eye damage,” along with specific precautionary statements based on the classification. These statements also provide specific instructions for prevention, response, storage and disposal of the chemical.
Applicable pictograms, hazard and precautionary statements are required elements of a shipped container label, and are included in Section 2 of an SDS. It’s part of your obligations to ensure that your workforce is familiar with this information and where to find it, and that you’re actually using this information in your emergency planning.
Cultivate good relationships with your local emergency response personnel. It’s a good idea to make sure they know exactly what chemicals you have stored, and where they’re stored, so that there’s no time wasted or extra risks taken in the event of an emergency. Modern EHS software can make sharing this information much easier by facilitating mapping of chemical storage locations onto a footprint of your facility.
Of course, beyond any individual regulatory requirements, emergency planning is really about identification and control of risks to your people and to the larger community. For example, when it comes to chemical safety, go beyond simple compliance to focus on having the best hazard information readily available when you need it most. Modern software-based Emergency Response Services (ERS) can make a big difference there, and save crucial time in accessing hazard information in the event of an emergency.
For more information on general emergency planning requirements, please check our free webinar.
Train Your Workers
All of the elements of HazCom management we’ve talked about so far are important, but will only be effective to the degree that you’ve trained your employees on them, and that they’ve actually understood the training.
Make sure you’re not only training all your employees before they work with hazardous chemicals, but whenever you identify significant changes to your chemical hazards and management practices, or whenever you see evidence that employees have not understood the training or have forgotten the information covered in training. Your training needs to include proper storage and handling procedures, including those for incompatible chemicals, and procedures to follow in the event of a spill or other chemical emergency.
Remember, comprehension is key. Make it standard practice to allow your employees to ask questions during training and to evaluate their understanding of HazCom, not just immediately after the training but on a recurring basis during normal workdays.
Put it in Your Written HazCom Plan
Having a Written HazCom Plan is not just a requirement for employers under the HazCom Standard. It’s also a chance work out the logic of your HazCom management program in writing and to make sure all elements of your program are accessible to your employees. In other words, it’s supposed to be a paper exercise. It needs to be your playbook.
Remember that the plan has to be specific to your hazards, your management practices, and your program details at your establishment. Additionally, make sure you’ve spelled out who is responsible for key aspects of your program. A 2015 enforcement directive makes clear that OSHA expects your plan to designate the individuals responsible for managing labels on shipped containers, and workplace labels, and for obtaining and managing access to SDSs.
Once you have a Written Plan in place, keep it up to date, and make sure your employees know where to find it. When I was a Global EHS Coordinator, I used to find it useful to casually ask employees I passed walking through the facility if they knew where to find the HazCom plan if they ever wanted to review it. Many times, they knew exactly where and how to do that, but other times they didn’t. That usually meant that it was time for at least a quick refresher on the basics of the program with their department, and that it might also be a good idea to review the details of their HazCom training program to see what reasons may have contributed to the gap in awareness. Gaps create safety risks.
If you need help writing a HazCom Plan, or would you just like to make sure your existing Plan has everything it should, click here to check out our written HazCom Plan template.
Chemical accidents like the one that took the life of this restaurant manager are sad, and scary. HazCom management is about putting our best planning forward, and being willing to find places where we can improve. With the right plans and the right tools, we can minimize the potential for chemical accidents and create a safer workplace.
Let VelocityEHS Help!
If you are looking for help improving your HazCom management, VelocityEHS has you covered.
- MSDSonline SDS/Chemical Management Platform: Newly updated with more than 350 added and improved features to streamline chemical management and regulatory reporting. Ensure your employees have right to know access to your inventory of safety data sheets-- online or offline-- with our cloud and mobile-enabled Chemical Inventory Management Solution and SDS Chemical Inventory App. Ingredient Indexing provides visibility into the actual ingredients in your chemical products to strengthen and simplify storage, handling and emergency response procedures.
- Emergency Response Services: Sign up for our Emergency Response Services for access to our 24-hour federally and globally recognized Emergency Response Communication Call Center—powered by ChemTel—for hazardous material shipping compliance, lithium battery shipper support, exposure support, and right-to-know SDS access.
- SDS Authoring: if you have a need for hazardous chemical products or Ingredient Disclosure Documents to be classified, authored, translated or reviewed for compliance with various regs, or for safer ingredient substitutions, let our team of experts help.
Contact us today to learn how more about all of the ways we can help with chemical management, emergency planning and reporting. As always, we wish you many safe and happy days.