The Federal and state offices of OSHA require full disclosure to employees about any hazardous substances with which they are required to work. Clearly, this specifically applies to your Housekeeping, Food & Beverage, and Maintenance staff and could apply to others should they come into contact with any hazardous substances in the course of their job.
You have the Material Safety Data Sheets on the chemicals you order. These come with the chemicals you receive. However, we are required to do more with respect to full disclosure than simply having these sheets available and training the employees on their use. This memo explains the extent of our obligation. Here is what you need to be doing and you MUST document it when you do it.
- List all hazardous substances; be sure to keep the list current.
- Make sure that you have a Material Safety Data Sheet for all of the hazardous substances on your list. The manufacturer will send you those you are missing. Make sure to get one when you get anew hazardous substance.
- Make sure all hazardous substance containers are labeled.
- Train all of your employees on proper and safe use of all hazardous substances before they begin to work with them. All of this information is found on the Material Safety Data Sheets. Training is to include:
- Chemical and physical properties of materials and methods that can be used to detect the presence or release of chemicals (including chemicals in unlabeled pipes).
- Physical hazards of chemicals(e.g. potential for fire, explosions, etc.)
- Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
- Procedures to protect against the hazards (e.g. personal protective equipment required its proper use, and proper maintenance, work practices, procedures for emergency response).
- Work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks.
- Where Material Safety Data Sheets are located, how to read and interpret the information on both the labels and these sheets, and how employees may obtain additional hazard information. This would be to contact their direct supervisor and/or the General Manager who will contact the manufacturer if necessary.
- Be sure you document this training (who, what, when) -everything is lost if you fail to document this training.
- Make sure that the Material Safety Data Sheets are easily accessible to all employees working with these substances. The location of the documents should be close to their immediate work area.