By Patrick White 2016-01-25 21:48:36
Do your team members understand pictograms, safety data sheet documentation, PPE advisories and other standard safety communications? KEEPING THE FOOD WE EAT SAFE TO EAT REQUIRES STRONG STUFF. Oh, not just the dedicated team of school nutrition professionals who follow myriad food safety protocols, but literally strong stuff: powerful chemicals used to clean and sanitize a foodservice kitchen. Used improperly, the materials used to kill foodborne pathogens and keep pests at bay can kill you, too. Kitchen chemicals present both health hazards and physical hazards. That’s why there are so many precautions about the proper use of such dangerous materials, and why you and your team members must understand how to handle them with care. Clarified Communications If you’ve got a lot of free time (in this profession? ha!), you can go online and read every bit of the Occupational Safety and Health Administration’s (OSHA) recently updated Hazard Communication Standard. It’s mind-numbingly dense, full of appendices and “subparts.” Some sections resemble the appearance of DOS computer code. It’s not light reading. Fortunately, School Nutrition boiled down this whole complicated subject in its January 2014 issue (Playing It Safe, “Chemical Compliance”). Here’s an even more streamlined recap: OSHA’s new standards are based upon a “Globally Harmonized System” of communicating hazards created by the United Nations. “That international standard was created to reduce accidents and deaths,” explains Caryn Stets, SFSPac regulatory compliance director for PortionPac Chemical Corporation. “When it passed this new standard in 2012, OSHA estimated that 500 accidents and 43 deaths would be avoided each year upon complete implementation.” Rather than relying on chemical manufacturers to use their own language to communicate the hazards present in their products, OSHA is now using standardized language and criteria. Chemical manufacturers have had to reevaluate their cleaning products using these new criteria, and then develop highly specific instructions to users based on the new language. Up until now, the communications burden has been on the manufacturers. But beginning on June 1, 2016, the onus shifts to employers—including school nutrition operations). “This part of the new regulations falls directly, squarely, on the shoulders of employers,” says Stets. It requires them to: • educate employees on the newly classified hazards present in the products they use on the job; • have, and maintain, compliant “workplace containers” (any container that is continuously used in the workplace); and • have a hazard communication plan that is kept at each workplace in an accessible location. “There were no changes to the standard as far as hazard communication plan requirements,” reassures Stets. “But this is an opportunity to go through your plan, and go through the standard, to make sure that it is compliant.” Likely the most time-consuming step is the requirement to educate all employees about the hazards and the chemicals that they’re using. “Every hazard that the employee may be exposed to needs to be taught to the employee,” stresses Stets. And because all of the standards for labels and hazard warnings have changed, employees will need to be trained to understand the new labels and accompanying paperwork. Time (Again) for Training “The focus has never been to this detail regarding hazards and chemicals,” says Stets. Even for those with a solid HACCP and kitchen safety background, some of these hazard descriptions—“combustible dust,” “simple asphyxiant,” etc.—are likely to be unfamiliar. “They are absolutely new terms,” she notes. Pictograms (more on this later) are also new. So be prepared to learn some unfamiliar concepts and terminology. For managers and directors, it’s also important to realize that achieving compliance with the new training standard is going to be something of an operational headache. “You’ve got directors who have Child Nutrition Reauthorization coming up, they’ve already got all of these meal plan changes, they’ve got all of the new professional standards that they have to manage, and now they have this—I think it’s going to be a burden,” admits Stets. “In the short term, this is going to disrupt everything in terms of chemical usage. In the long term, the more I use it, and now that I’m teaching how employers can get across the information to the individuals who are using the products, it clicks.” In the event of questions or confusion, or if basic training assistance is needed, Stets encourages schools to seek training assistance from the manufacturers of their cleaning products. “We go in and teach our customers when they ask us. So lean on your manufacturers—don’t take it all on yourself,” she says. First Things First Before you can even begin to devise trainings for employees based on the new OSHA standard, it’s important to know what chemicals and products are being used in your schools, advises Stets: “Do your homework and go through every single chemical to determine the hazards.” During this step, Stets encourages directors to “delegate, delegate, delegate.” Directors need to partner with their chemical manufacturers to gather hazardrelated information, and work with their managers to take stock of what’s really in the schools, she explains. This process gives school districts an opportunity to consider removing certain products—maybe those, for example, that have the potential to harm an unborn child, which is one hazard category in the newly revised standard—from schools. “It’s better to be able to say, ‘We found this out, and we’re removing this product,’ [before training begins] rather than saying, ‘We’re going to educate you about all these hazards and then having someone stand up and say, ‘I’m pregnant,’” advises Stets. (To be fair, it’s unlikely that a cleaning product designed for use in a kitchen would carry that particular hazard classification, but a pesticide may.) “As a director, you don’t want to be caught flat-footed if a product that has been newly classified comes with a hazard that is unacceptable to the district,” says Stets. Because the whole system is new, there are no uniform rules as to which hazards are allowed in school districts—and which are not. Rather, it is up to each operation to determine acceptability. But don’t be complacent. Just because you’ve used a certain product for years and feel comfortable with it, don’t assume that it doesn’t have “new” risks, based on the changed criteria, which may surprise you. Simpler May Be Better Ask managers at each site to gather the information about all of the specific products being used. “Step one is to gather the information about what you have in the schools. Take a look at it. You may want to then communicate back to the managers to get rid of this product and this product and this product,” advises Stets. Not just because there may be some products with hazards that are deemed unacceptable, as noted above, but simply because there are so many different hazards that training will become overly complicated. If 75% of your products fall under only two pictograms and four hazards, and the other 25% are made up of a whole bunch of different individual pictograms and hazards, it may make sense to make some different product decisions based on that knowledge. The fewer pictograms and hazards involved, the more palatable the training involved will be, notes Stets. Standardizing the products used across the district can also save money not only through simplified training but also by increasing buying power and reducing the number of accidents and lawsuits that could occur if there’s a random product with an unusual hazard. Once you have narrowed the field products and hazards present in your school, you can make the training process more efficient by training only on the hazards that are present in the products that are actually being used in the program. “That way you can push away all of the noise,” says Stets. (The aforementioned “combustible dust” hazard is just one example that’s unlikely to be encountered in school kitchens.) OSHA appendices have entire spreadsheets of hazards, but your district may only have five to guard against. So you only have to “drill down” on those five when training, she notes. That makes things simpler for trainers, and for employees. 2-4-8: A Training Approach That’s Just Great Another way to simplify training is to narrow the list of sections of the OSHA standard that you will focus on. When you’re looking at an SDS (safety data sheet) for a particular chemical, it features 16 sections, “and that is really overwhelming,” concedes Stets. She recommends a “2-4-8” approach, which is both easy to remember (2 plus 2 is 4; 4 plus 4 is 8) and covers the most critical sections. “Section 2 communicates the classification of the product according to OSHA’s new standard. So, if the product has a hazard, it’s going to have a pictogram, the hazard statement and all of the precautionary statements,” explains Stets. “Section 4 has all of the additional first aid instructions that the manufacturer wants the user to be aware of in the event of an accident. Section 8 is where the user will find required PPE (personal protective equipment).” The 2-4-8 method is also an effective way to provide first aid training. When training on first aid, Section 2 should be the first place to focus, because it explains how to respond in the event of an accident, based on the hazard(s) that OSHA says applies to that product. “So, if the chemical is an eye irritant, in the precautionary statement response section, it’s going to say something like ‘rinse cautiously with water,’” says Stets. Section 4 will be the source of any additional information. “Let’s say the manufacturer thinks that, after flushing, you really should call your physician to make sure you’re OK. You really want to look at both sections,” she emphasizes. Similarly, Section 8 may include information on PPE not required by the OSHA standard but recommended by the manufacturer. Or it may include a direction from the manufacturer for the user to wash their hands after using the product, which may not be part of OSHA’s communication. That’s why it’s important not to rely solely on Section 2 and forego Sections 4 and 8. As for the other sections, “They’re important and there’s a lot of information in there,” says Stets, “but let’s be realistic.” Incorporating too much information in your training increases the likelihood that an employee will forget more critical elements. “Those using the products are just not going to be able to remember it all, and I want them to be as safe as possible, in that moment when they need it,” she concludes. Managers and directors may need to be aware of other sections. Section 5, for example, covers fire fighting; 6 and 7 cover, respectively, accidental release measures and handling and storage. A district with a central warehouse may need to train certain employees on Section 14, transportation information. Disposal considerations (Section 13) is another section that may be relevant to certain staff responsibilities. Finally, some sections may be relevant in certain states with regulations regarding safe drinking water and other environmental laws. Picture This One basic topic that must be covered in any kitchen chemicals training is OSHA’s new pictograms. These symbols are used to convey the potential dangers of a given product, so that anyone with English literacy barriers can be aware of the hazards. Seeing an “exploding bomb” or a “skull-and-crossbones,” two examples of pictograms in the new standard, may create anxiety for employees. “Employees are going to be very surprised when they start to see pictograms that communicate hazards in products,” warns Stets. “An employee is going to be concerned about themselves and their family’s health. Any pictogram that communicates a potential hazard to that individual is going to big red flags, and may be an issue.” But while the pictograms may create some anxiety for you or your staff members, they are effective, she insists. People remember pictograms, especially when they’re so bold. “For some reason, that sits in their heads,” Stets claims. “So I would start there, by identifying the pictograms that employees are going to see, and then provide examples of a product label with a pictogram, then a workplace container with a pictogram and then an SDS with a pictogram.” Next, Stets recommends telling the employees a story of how they can use this visual detail. “In the case of an eye irritant, right there on that product it’s going to say that you need eye protection. You no longer need to refer to the SDS,” she explains. Or, if there’s a spill, the proper procedures and precautions will be described and can be brought to life in a training. The idea behind the new standard is that most incidents happen while the product is actually in the hands of the employee, so the new information is designed to empower them to take the right action, without delay. “That’s what I would teach employees,” notes Stets. “What are those response statements that are tied to a particular hazard? Before you even pick up that product, you need to read these very clearly communicated statements that are standardized for that hazard.” On the Safe Side Although training techniques, hazard descriptions and pictograms on chemical products might have changed, the severity of having up-to-date knowledge on chemical safety has not. Training the entire staff not only helps guard against potentially life-threatening incidents, but also ensures that everyone knows how to respond when a situation occurs. And while the new documentation mandates might seem intimidating, they’ve truly been streamlined for your benefit and protection. All it will take is a little bit of adjustment, and you can be sure that everyone in your operation stays safe when it comes to handling chemicals. Avoid Outside Variables One thing that can doom even the most well-orchestrated chemical safety training plan is the habit of individual employees to bring in to work with them cleaning products that they prefer or use at home. “That has always been a big no-no, but now more so than ever,” says Stets. Any chemical used in a school setting is required, by law, to have a corresponding SDS (safety data sheet). But the retail market doesn’t require an SDS. While it’s possible to contact the manufacturer to get one for use in a school foodservice kitchen, sometimes the manager or director isn’t aware that an outside product has been brought into the kitchen. With many sites under your purview, it may be difficult to police, but remind your site managers to stay vigilant and not to compromise. Not only is it dangerous and against regulatory requirements, but health inspectors will be on the lookout for this infraction. Keep It Contained Many cleaning products are provided as a concentrate, which is then diluted onsite at schools. Beginning on June 1, 2016, any workplace containers that the product is placed into also need to be compliant with the new standard. “If it’s a bucket and the product gets used up and disposed of, it’s not a big deal,” says Stets. But if it’s a spray bottle that you’ve mixed the solution in one day and put on the shelf for use the next day, that’s where the new standard kicks in. The original concentrate container shipped from the manufacturer is required (as long as it’s not old stock received before June 1, 2015) to have a current, compliant label. And the standard now says, among other requirements, that “the workplace container product identifier must be in English and match the SDS, which must also match the primary container.” “I’m guessing that the majority of chemical manufacturers will provide those containers to the schools—if that is the case, then the school is responsible for maintaining them,” Stets explains. “If the name of the product rubs off, they need to replace it, for example.” Are You Protected? “If you went into most school foodservice kitchens today, I am going to guess that employees are not regularly wearing safety glasses when using products that require them,” asserts Stets. “You would probably find them wearing gloves, because employees use these to protect their hands when they’re washing dishes. But I think that splash hazards are one of the biggest dangers with chemical use, because people aren’t putting glasses on,” she reports. From a training perspective, the new OSHA standards are helpful by removing any question of what PPE is required. “If it’s in Section 2, it will says ‘wear eye protection.’ So it’s not a manufacturer or a lawyer advising it; this is OSHA saying that it’s required, and it’s right there on the product label—you don’t have a choice anymore,” Stets explains. If a health inspector came in and an employee was using a product that said to wear eye protection without this PPE, that violation could be flagged. Patrick White is a freelance writer based in Middlesex, Vt., and a former assistant editor of this publication. SNA members can view Caryn Stets’ related 2015 ANC presentation by visiting www. schoolnutrition.org/anc2015presentations and logging in. Photography by Thinkstock.com.
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