OSHA Hazard Communication Program:  State and federal regulations require that the all employers provide a Hazard Communication program for all employees exposed to hazardous chemicals at work.  The program must include elements as follows:

• Employee Training
• Written Program
• SDS for all chemicals used at the workplace (in certain instances for chemicals sold at the workplace)- User Name & Password to access SDS on web are available to all clients
• Labeling of all chemicals pursuant to a protocol listed by OSHA.

You can access SDS currently listed on our web portal as follows:

Visit: www.cellyservices.com

UN:

PW:

The written program and employee training are available for all clients on the CSI portal and should be completed by all employees prior to their first shift.  The labeling of all chemicals is expected to be completed by the vendor or manufacturer pursuant to state and federal guidelines.  Employers must not have any unlabeled chemical bottles. Ask vendors for labeled secondary containers such as spray bottles.

Sanitizers & Disinfectants for COVID-19:  Employers are using a variety of disinfectant and sanitizers (hereafter referred as cleaners).  The disinfectants must be listed on the EPA website as effective cleaners against the virus.  https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2.  The list is being continuously updated by the EPA.  CSI investigated some of the SDS for sanitizers being used by employers.  We have concluded that these chemicals are stronger and more toxic than the ones used in the past.  We recommend that employers take some steps as follows:

• Provide a copy of SDS to employees followed by discussion on Personal Protective Equipment (PPE).
• PLEASE SEND US A PDF OF ALL THE SDS FOR THE DISINFECTANTS and ALL OTHER CHEMICALS NOT OUR WEB PORTAL to elearn@cellsyervices.com so it can be uploaded to your web portal
• Provide PPE to employees as listed on the SDS

Dilution Factors:  Disinfectants from vendors are in concentrate forms and must be diluted before use.  Dilution factors vary.  For example, the dilution factor for mold and mildew is greater than the one to be used for the COVID-19 virus.  More concentrated solution must be used in order to be effective against the COVID-19 virus.  The dilution must be completed by the shop foreman or senior technician using proper mixing tools and PPE.  PPE such as safety glass, face shield, apron and long rubber gloves are to be used in addition to the ones listed on the SDS for the disinfectant.

CA Law (Senate Bill 258) on Cleaning Products:  The cleaning products Right to Know Act of 2017 became effective on 1/1/2020.  The bill requires household, industrial, and commercial cleaning product manufacturers disclose information related to the chemicals contained in the product on the product label, the product’s Internet Web site, and provide a link to the SDS. Even though this requirement is not directed to end-users, we recommend dealerships get an SDS for each new chemical prior to its use and upload it to the web portal for easy employee access.

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.