When your hand sanitizer has 50% more Alcohol it will be at least a Category 3 Flammable Liquid – just review the SDS for your product of choice if you doubt me. In fact, some hand sanitizers with higher Alcohol percentages may be a Category 2 Flammable Liquid. In the light of COVID-19 virus pandemic, these products are being hoarded in large quantities by individuals and I can assure you that 18,000 PLASTIC bottles of hand sanitizer stored in a garage are a neighborhood disaster waiting to happen. But how about all these businesses that have erected the hand sanitizer stations? What should they be doing to ensure they are storing and handling these materials safely and what training should employees be receiving when these materials enter a workplace?
First, the vast majority of these hand sanitizers come with a Safety Data Sheet (SDS) as they are indeed flammable liquids. However, as far as OSHA goes, these flammable materials may be exempt from 1910.1200. OSHA does not require that MSDSs be provided to purchasers of household consumer products when the products are used in the workplace in the SAME MANNER THAT A CONSUMER WOULD USE THEM (i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience). This exemption in OSHA’s regulation is based, however, not upon the chemical manufacturer’s intended use of his product, but upon how it actually is used in the workplace. Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the properties of those hazardous chemicals.
Regardless of the SDS exemption, employees will need training on these products; especially training on the proper storage of these CAT 3 flammable liquids. Remember, flammable storage cabinets are LIMITED to 60 gallons of CAT 3 flammable liquids and trust me, the boxes these sanitizers are shipped in will fit neatly inside a large flammable cabinet and when the cabinet is full, it will be OVERLOADED with more than 60 gallons of CAT 3 Flammable Liquids. Also, these CAT 3 flammable liquids are LIMITED in how much can be in the workplace AND OUTSIDE of the cabinets and/or inside-flammable storage room. A facility can have 120 gallons of CAT 3 flammable liquids out for use per FIRE AREA and in most office settings the FIRE AREA will be the entire floor/level of the office building. Now realize 120 gallons of hand sanitizer is a heck of a lot of sanitizer and to need that much per floor would be a densely occupied floor. I have been unable to find anyone who provides an estimate an employee would need over an 8-hour shift if he/she followed the usage guidelines.