Is an empty jar of non-dairy creamer really an appropriate container for bleach? How should this hazardous substance be stored?
When a hazardous substance is present in the workplace, it’s important that it’s properly labeled so that workers know what kind of substance it is, what health and safety hazards it poses and the proper precautions to take when using it. That’s why the WHMIS system exists, in fact, and requires labels meeting specific requirements on substances deemed “hazardous products.”
In some cases, workers may need to pour hazardous substances from their original containers into smaller, more manageable ones. But as this picture of various containers in a school lab illustrates, using food containers such as jars of non-dairy creamer to hold hazardous substances isn’t appropriate or safe. For example, the fact that powered bleach and non-dairy creamer look similar exacerbates the risk that someone might pour some of the bleach into his coffee and take a big swig.
Look what happened to a worker who found a liquor bottle filled with methanol windshield washer fluid. The bottle still had the liquor label on it. So he and a co-worker drank from the bottle; one took the bottle home and finished it. He later died from methanol poisoning. The employer pleaded guilty to failing to acquaint a worker with a hazard in the handling, storage or use of a liquid chemical agent and was fined $175,000 [Brewers Retail Inc., Govt. News Release, Feb. 15, 2013].
Hazardous Substance Decanting Label Requirements
Under WHMIS 2015’s label requirements, so-called “hazardous products” must have either a:
- Supplier label provided by the company that sold, imported or distributed the product; or
- Workplace label provided by the employer.
A workplace label is needed in several circumstances, most notably when a hazardous product is “decanted” or transferred from its original container bearing a supplier label into another, often smaller container. In that case, the employer must affix a workplace label to the second container (there are limited exceptions to this requirement).
A workplace label must generally include:
- A product identifier identical to that found on the safety data sheet (SDS) for the hazardous product;
- Information for the safe handling of the hazardous product; and
- That a SDS, if supplied or produced, is available.
Yes, someone relabeled this jar, “Bleach, Do not touch.” However, this handwritten label doesn’t satisfy the requirements of a workplace label because it doesn’t contain all of the necessary information. (The presence of the old Carnation label still on the jar just adds to the potential confusion.)
So it’s important to train workers on the proper steps to take when transferring a hazardous substance into another container as part of your WHMIS 2015 training. (This chart tracks the progress in each jurisdiction in Canada on the implementation of WHMIS 2015 into their OHS laws.)
6 Key Elements of Safe Hazardous Substances Storage
In addition to ensuring that hazardous substances are properly labeled, make sure that you also comply with the requirements for storage of hazardous substances in your jurisdiction’s OHS law. There are six basic elements of safe storage:
- Inventory. Take an inventory to determine exactly how many hazardous substances are used, handled or stored in your workplace, what kinds and in what amounts.
- Storage area. Designate an appropriate area for storage of hazardous substances. Your storage area can be as small as a cabinet or as large as an entire room or even a building. The designated area should meet certain criteria, such as it should be fire-resistant and have adequate ventilation and lighting.
- Quantities. To reduce the effects of any incident involving hazardous substances, try to limit the quantities you keep on-hand.
- Storage methods. Within the designated area, ensure that safe methods are used to store the hazardous substances. For example, keep incompatible substances separate, ensure containers aren’t damaged and store heavy containers are lower shelves.
- Labels. As discussed above, ensure that all containers of hazardous substances are properly labeled. Replace any labels that are missing, damaged or illegible.
- Signs. The storage area, room, cabinet or building should be clearly identified as containing hazardous substances with signs, placards or similar means of identification.