As a result of the COVID-19 pandemic, many businesses and workplaces are now using and supplying hand sanitiser as a control measure against the risk of transmission of COVID-19. Alcohol-based hand santisers, and some of their ingredients, can be considered hazardous chemicals. For example, ethanol and isopropanol are flammable liquids and can cause severe eye irritation, and hydrogen peroxide is corrosive to the skin and eyes.
What is a Safety Data Sheet?
A Safety Data Sheet (SDS) is a document that provides important information about hazardous chemicals and is used to assess and manage risks associated with the use of hazardous chemicals in the workplace. It includes information on:
- the chemical's identity and ingredients
- health and physical hazards
- safe handling and storage procedures
- emergency procedures, and
- disposal considerations.
Duties to obtain and ensure access to Safety Data Sheets
Under section 344 (1) and (3) of the Work Health and Safety Regulation 2011 (WHS Regulation), a person conducting a business or undertaking (PCBU) is required to:
- obtain the current SDS for a hazardous chemical from the manufacturer, importer or supplier, and
- ensure that the current SDS for a hazardous chemical is readily accessible to workers involved in using, handling or storing the hazardous chemical at the workplace, and an emergency service worker who is likely to be exposed to the hazardous chemical at the workplace.
A hazardous chemical is a substance, mixture or article that satisfies the criteria for a hazard class in the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS). Further information on the GHS is available from Safe Work Australia.
When is a Safety Data Sheet not required?
Under section 344(4) of the WHS Regulation, there are a number of exceptions for complying with the requirements relating to Safety Data Sheets. For the use and supply of hand sanitiser in the workplace, a PCBU does not need to obtain the current SDS and make it readily accessible in the following circumstances:
- where the PCBU is a retailer and they stock hand sanitiser as a consumer product;
- where the PCBU purchases hand sanitiser from a retailer and it is reasonably foreseeable that it will be used in quantities consistent with household use and in a way that is incidental to the nature of the work carried out at the workplace.
Where hand sanitizer is used in an office environment or on a construction site, it is reasonably foreseeable that it will only be used in quantities that are consistent with household use and that it is purchased as a consumer product. It therefore does not require an SDS or to be registered in the PCBU's hazardous chemicals register.
A construction company purchases several 750mL bottles of hand sanitiser from their local supermarket to provide to workers at their worksite.
The 750mL bottles are consumer products and considered to be intended for domestic use only. The use of the hand sanitiser is also considered incidental to the nature of the work being carried out, as the construction worker is not required to use hand sanitiser in order to carry out their work.
It therefore does not require a current SDS to be obtained and to be made available at the worksite. Health and safety information is available on the container's label.
A commercial cleaning business purchases a 20L container of hand sanitiser from a local manufacturer. It is reasonably foreseeable that, due to the package size, this would be used in a workplace setting rather than in a domestic situation.
Therefore, the 20L container will require an SDS and registration in the PCBU's hazardous chemicals register.
Safe Work Method Statement requirements for hand sanitisers in the workplace
Under section 299 of the WHS Regulation, a PCBU carrying out high risk construction work must ensure, before work commences, that a safe work method statement (SWMS) is prepared or has already been prepared by another person.
A SWMS must identify work that is classed as 'high risk construction work' and state hazards and risks relating to the high risk construction work, and how these will be managed. High risk construction work is defined under section 291 of the WHS Regulation.
As the use of hand sanitiser is incidental to the carrying out of construction work, it would not be considered necessary to incorporate risks associated with hand sanitiser as part of a PCBU's SWMS. However, there are regulatory requirements that would apply to any PCBU who is manufacturing their own alcohol-based hand sanitisers.
You can read more information about alcohol-based hand sanitiser manufacturers.