Hazard communication programs are essential for any operation in which hazardous chemicals are used. When developing a hazard communication program for your food service operation, be sure you follow all standards set by OSHA, specifically Standard 1910.1200. This standard ensures that information regarding the hazards of any chemicals produced or imported is communicated to all workers by way of a comprehensive hazard communication program. This shall include container labeling and other warnings, Material Safety Data Sheets (MSDS) and employee training. Essentially, there must be proper labels, written warnings, MSDS and employee training in place.
What is in a Written Hazard Communication Program?
Proper Labels. Although the employer is not required to label portable containers into which hazardous chemicals have been transferred, it is helpful to appropriately label every container to provide additional information about the chemicals contained within. Signs, operating procedures or other informational material can be posted on the walls to help identify chemicals used on the premises. Appropriate hazard warnings, words, pictures, symbols to provide specific information regarding the physical and health hazards of that chemical.
Hazardous Chemicals. According to the Occupational Safety and Health Administration (OSHA), hazardous chemicals are any that could potentially cause a physical or health hazard, specifically pertaining to chemicals with carcinogens, or toxins, such as chlorine, ammonia, formaldehyde or ethanol. OSHA provides a full list of chemical types that are considered hazardous, including the following:
- Toxic agents
- Reproductive toxins
- Agents damaging to lungs, skin, eyes or mucous membranes
Material Safety Data Sheets
MSDS Requirements. You must have a Material Safety Date Sheet (MSDS) for every hazardous chemical on the restaurant premises. When you order chemicals for the first time, the chemical manufacturer will often provide the appropriate Material Safety Data Sheet from the chemical manufacturer. Every MSDS must include the following information, in any order:
MSDS must include the following information:
- The chemical and common names of the substance
- Physical and chemical characteristics of the hazardous ingredients (such as odor, appearance, vapor pressure)
- Physical hazards (such as combustibility)
- Health hazards (such as symptoms of exposure and any medical conditions exacerbated by exposure
- Primary means of entry (such as inhalation)
- The OSHA permissible exposure limit (such as the ACGIH Threshold Limit Value (TLV®)*)
- Precautions for safe handling and use (regarding storage, use and disposal)
- First aid and emergency procedures
- The manufacturer name
- Date the MSDS was prepared and contact information for the chemical manufacturer
MSDS are not needed for the following products:
- Tobacco products
- Wood or wood products (not including saw dust)
- Typically used consumer products (such as pens or pencils)
- Articles (such as plastic chairs)
- Personal food, drugs or cosmetics
- Retail food, drugs, cosmetics or alcohol
- Drugs in solid form (such as pills)
* The American Conference of Governmental Industrial Hygienists (ACGIH) determines that exposure to a chemical at or below its TLV® will not create unreasonable risk of injury or illness.
Since OSHA standards mandate employee training within a hazard communication program, you need to implement training procedures in your restaurant. The best way to do this is to introduce all new employees to the chemicals you have on hand, procedures for how to use them safely, and how to use the material safety data sheets in case of a crisis. Make sure the following training points are included in all employee training:
Teach employees to use MSDS. First off, teach your employees where to find the MSDS. In a critical situation, they need to know where the MSDS is located, how to look up the chemical in question, and how to read the chemical information.
Point out labels and posters. All original containers should be labeled appropriately, identifying the chemical inside. Be sure all employees know how to read and understand the chemical information on the label, as well as any procedures or warnings on the posters.
Demonstrate proper use. Perhaps the most important part of training is the opportunity to demonstrate the correct usage of all chemicals. This is particularly important for brand new employees, but can also be a good refresher for seasoned employees.