Do I need a Safety Data Sheet for that washer fluid at work?
Washer fluid is considered a consumer product and there are many products you may use at work (WD-40, paint, brake cleaner, toilet bowl cleaner) which have been purchased at a local home improvement store. Consumer products are exempt from hazardous product regulations like WHMIS and HazCom. This means they are not sold with a Safety Data Sheet and product label. But this doesn’t mean they are not hazardous. Some consumer products can have carcinogenic and reproductive hazards. Some are skin and respiratory sensitizers.
So why are consumer products managed differently than hazardous products if they still have hazards?
In an occupational setting product use is different than product use at home. The product quantity is usually greater in an occupational setting. The frequency of use can be higher. The application of the product can also change in an occupational setting. For example, at home you may apply paint with a paint brush. In some workplaces, you may use a paint spray machine during a whole shift, every day for a week. Any and all of these changes (the application, task duration and use of the hazardous product) changes its risk profile.
It comes down to assessing the risk of the product and the task it is intended for by asking yourself a few questions:
- Is the consumer product used in a greater quantity in the workplace than it would be at home?
- Is the consumer product used more frequently in the workplace than it would be at home?
- Is the application different than the consumer product use or is it applied differently than it would be at home and therefore may have new hazards with the new application?
Answering these 3 basic questions will provide you an idea if the risk has gone up because we know that quantity, frequency and use all affect the risk level of any product and subsequently you may then require additional controls to control the hazards.
There may be other factors like emergency preparedness you need to consider in your assessment if a Safety Data Sheet is required for a consumer product.
In the workplace, organizations need to be prepared for first aid, spills and fire situations. Most workplaces require an up-to-date chemical inventory, and this should include your consumer products. These reasons may justify the need for a Safety Data Sheet. Most manufacturers of consumer products have Safety Data Sheets for their products. Chemscape supports our customers by sourcing and maintaining consumer product SDSs.