Chemicals in the Workplace: COVID-19 Cleanup Considerations

The ongoing global pandemic involving the novel coronavirus SARS CoV-2 that causes COVID-19 is creating an urgent need for disinfectant usage. Frequent cleaning of potentially contaminated surfaces is essential to limit the further spread of the virus. EPA has provided some direction by publishing a list of disinfectants recognized to be effective against SARS CoV-2 here. However, the increased scale of disinfectant usage creates new challenges we need to address to avoid creating additional safety risks.

Let’s review some key considerations for safely managing disinfecting chemicals in your workplace.

HazCom Management

Some cleaning chemicals are commercially sold products that have often been exempt from regulation under OSHA’s Hazard Communication (HazCom) Standard. Section 1910.1200(b)(6)(ix) specifically exempts consumer products and hazardous substances, as those terms are defined in the Consumer Product Safety Act and Federal Hazardous Substances Act, when the usage of those products in the workplace “results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers.”

In other words, when employers limit workplace usage of these chemicals to the kind of occasional, small-scale applications typical of an average consumer’s usage, the chemical usage is not subject to HazCom requirements such as the need to maintain safety data sheets (SDSs), a written HazCom plan, a chemical inventory list, workplace labeling system, or provide HazCom training to workers.

Things are different now. More frequent usage of chemical cleaning products may often nullify the consumer exemption that once applied to these products. If you have any doubt at all about whether cleaning chemical exposures have passed beyond the range expected for the average consumer, it’s best to err on the side of caution, assume the HazCom Standard applies, and begin planning how to meet your obligations. Prioritize obtaining copies of SDSs for the applicable chemicals and providing HazCom training to all workers who use these chemicals and generate compliant workplace/secondary labels as needed (think of instances when you’re transferring product from larger containers to smaller ones and possibly diluting the chemicals). For an overview of employer responsibilities under the HazCom standard, check out our Intro to HazCom series or our on-demand HazCom webinar.

One of your employer obligations under the HazCom Standard is to provide your workforce with access to SDSs within their workshift. That can be a challenge under normal conditions, but may be even more difficult during the present pandemic as social distancing measures and reduced in-house staff cause workers to be more geographically separated than usual. Consider the benefits of a cloud-based and mobile chemical and SDS management system for making your SDSs available from anywhere at any time.

Avoid Incompatible Chemicals

Once we have SDSs in place for cleaning and disinfecting chemicals, we need to actually use the information in them to inform our everyday storage and usage practices.

I especially recommend paying attention information in Section 7 of the SDS, pertaining to precautions for safe handling and storage. This section contains important information that you and your workers need to know to be able to use the chemicals safely, including incompatible chemicals to avoid.

There is a history of workplace accidents caused by mixture of incompatible cleaning chemicals. One example, as we’ve previously discussed, is a 2019 incident at a popular chain restaurant in which a reaction between common, but incompatible cleaning chemicals, released toxic fumes that resulted in the death of a supervisor. That incident happened when a worker began using a cleaning product to clean a floor that still contained residue of an earlier spill of a different cleaning chemical.

These types of accidents happen under normal conditions, and conditions right now are far from normal. The understandable urgency behind cleaning and disinfecting efforts to flatten the COVID-19 curve is resulting in much more demand for disinfecting products than usual, as well as a scarcity of available products. These two factors create a potential for more chemicals to be used without a thorough understanding of the hazards, or for mixing and matching of different products that may in fact be incompatible.

I’ll point out here that there appears to be a real chance that something like this might happen based on my review of EPA’s list of disinfectants recognized as being effective for use against the novel coronavirus. EPA’s most recent version of the list is available here. The table below contains a small partial sample of this list, for discussion purposes.

EPA Registration Number	Active Ingredient	Product Name
10324-105	Quaternary ammonium	MAQUAT 128 PD
1677-129	Hydrogen peroxide; peroxyacetic acid	COSA OXONIA ACTIVE

EPA of course does not endorse using multiple products on its list together, and only intends through publishing the list to make sure “Americans have greater access to as many effective and approved surface disinfectant products as possible and that they have the information at their fingertips to use them effectively,” in the words of a recent news release regarding the list.

Still, we need to take care to avoid potential incompatibilities. If we take a look at the table above, we see the active ingredient for the first disinfectant (Maquat 128 PD) is listed as being quaternary ammonium. Quaternary ammonium compounds are a broad class of chemicals derived from an ammonium ion by replacing hydrogen atoms with organic radicals, used widely as surfactants and disinfectants. They function as strong bases in acid-base reactions and also react with strong oxidizers.

The potential problem is apparent when we look at the active ingredients for Cosa Oxonia Active, which are hydrogen peroxide (an oxidizer) and peroxyacetic acid (an acid). Both of those active ingredients have the potential to react with quaternary ammonium compounds. Quaternary ammonium compounds also can react strongly with chlorine and release toxic gases as indicated in this incident report. Many common cleaning/disinfecting products, including bleach, contain chlorine. Reactions and intensity may vary depending on the concentrations and specific ingredients involved, which drives home that we not only need to obtain SDSs and make them available to our workforce, but also be familiar with information in Section 7 and apply it to the chemicals in our workplace.

Other potential chemical incompatibility situations to avoid include:

• Mixing bleach or sodium hypochlorite with acid, ammonia, or hydrogen peroxide. Remember that vinegar is an aqueous solution of acetic acid and so should not be mixed with bleach, or it will produce toxic chlorine gas.
• Mixing chlorine with ammonia, sodium carbide and turpentine.
• Mixing any acid with any base.
• Mixing hydrogen peroxide with ammonia, acetone, any base (e.g. caustic soda) or any flammable liquids, including many solvents.
• Using hydrogen peroxide on metal surfaces, especially copper, iron, or chromium.

This is not a comprehensive list. Consult Section 7 of your specific product SDSs for guidelines directly pertaining to your chemicals.

Of course, one additional challenge is that chemical product names often don’t offer many clues about the actual ingredients within. Consider the increased safety benefits of a software-based ingredient indexing solution for improving awareness of active ingredients and your ability to maintain safe usage and storage practices.

Industrial Hygiene and PPE Requirements

Knowing the contents of the SDS and the ingredients is also important for purposes of industrial hygiene (IH) management. Many of the active ingredients in these products will have established occupational exposure limits (OELS) such as an OSHA Permissible Exposure Limit (PEL), and you’ll need visibility of those ingredients to establish a sampling program, including establishments of similar exposure groups (SEGs) to streamline program management. Modern IH software can help with establishing your program from the bottom up, even if you have no previous experience in IH, giving you tools to select contaminants to be samples, choose analytical laboratories, manage medical surveillance where applicable, and communicate results.

Section 8 of the SDS contains important information regarding exposure controls and personal protection. For example, you’ll find information regarding proper ventilation and other engineering controls, and appropriate personal protective equipment (PPE). Because many workplaces will be in the position of having their workers use disinfecting chemicals they may never have used before, or using the chemicals far more frequently and in greater quantities, it’s important to be familiar with this information early and use it to make the workplace as safe as possible.

Emergency Response

Of course, even with all of the above elements in place, accidents can still happen. Chemical spills or other accidental exposures place your workers at risk, and you’ll need fast access to hazard information in the event of such emergencies.

A cloud-based SDS management system, as mentioned earlier, can provide fast access to SDSs from anywhere, including through usage of a mobile device. You can supplement that by working with service providers that provide emergency response services such as exposure support in the event of accidental releases, or access to a 24-hour call center to ensure that hazard information is always available when you need it most.

Summary

Let’s recap some of the key actions you can take to improve workplace safety involving disinfecting chemicals:

• Make sure you have SDSs for all chemical products that require one, keeping in mind that changes in the frequency and volumes of usage may negate the consumer exemption from HazCom requirements.
• Develop a plan for meeting all of your employer obligations under HazCom, including a written plan, maintaining an SDS library and providing access to it, maintaining a chemical inventory list, managing workplace labels, and conducting HazCom training.
• Determine how you will provide your workers with access to SDSs, while accounting for the fact that social distancing measures may cause more geographical separation within your workforce than ever before.
• Pay attention to Section 7 of the SDS, and follow instructions regarding proper storage and usage, including avoidance of incompatible chemicals.
• Identify which chemical ingredients in your products have established OELs, and include them in your IH program.
• Follow instructions in Section 8 for proper engineering controls and PPE to reduce risks of exposure.

This is an anxious time for all of us, but that’s all the more reason to do what we can not to compound our problems by creating additional risks for our workforce. As is the case in so many areas of life, plans we make now determine the plans we’re able to make in the future.

Let VelocityEHS Help!

We’re always happy to talk about how our chemical management module and supplemental Emergency Response Services can help you. Contact us anytime.

From all of us here at VelocityEHS, we wish you safe days, and hope for a better tomorrow.