2.3 OSHA Hazard Communication, Safety Data Sheets, Chemical Storage & Labelling

Hazard Communication, SDS, Chemical Storage & Labelling

Exam Focus: Expect items on the number of SDS sections, which agency owns which standard, and the New York-specific storage rules. The recurring trap is confusing OSHA with EPA: OSHA regulates worker exposure and communication, EPA registers the disinfectants. Know that New York separately requires original labelling to stay intact and flammables to live in a metal cabinet.

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1. Which Agency Does What

2. The Hazard Communication Standard

OSHA's Hazard Communication Standard — often called the "right to know" law — rests on the principle that a worker handling a chemical is entitled to know what it is and what it can do. It has four operative parts:

1. A written hazard communication programme describing how the employer meets the standard.
2. Labels on every container, carrying a product identifier, signal word, hazard statements, pictograms, precautionary statements and supplier information.
3. Safety Data Sheets obtained from the manufacturer for every hazardous chemical and made accessible to employees.
4. Training for employees on the hazards, the labelling system and how to read an SDS.

Since alignment with the Globally Harmonized System (GHS), labels carry standardised pictograms — the flame, the corrosion symbol, the exclamation mark, the health hazard silhouette — and one of two signal words: DANGER for the more severe hazard, WARNING for the less severe.

3. The Sixteen-Section Safety Data Sheet

Every GHS-compliant SDS has 16 sections in a fixed order. The order matters because a stylist reaching for the sheet during an incident needs to know where to look without reading the whole document.

The two sections a salon uses under pressure are Section 4 (first aid) and Section 8 (exposure controls and PPE). Section 7 tells you how the product must be stored, which is where the SDS meets New York's own rules.

4. New York Chemical Storage, Mixing and Labelling

19 NYCRR § 160.25 — Chemical storage and SDS

• (a) Any chemicals used in the conduct of appearance enhancement shall be mixed only in a dispensing area which has adequate ventilation. Mixing lightener at the styling chair is a violation, not merely poor practice.
• (b) Flammable and combustible chemicals shall be stored in a metal cabinet remote from potential sources of ignition, such as an open flame or an electrical device. Read this together with § 160.12's ban on candles, gas burners and cigarettes.
• (c) All nail care chemicals must be stored in closed bottles.
• (d) An owner shall have all Safety Data Sheets on file for inspection, maintained in written or electronic format so they are readily accessible to all employees, and shall ensure that all employees are aware of the location of, and have access to, the SDS.

19 NYCRR § 160.26 — Product labelling

• All products used in the business must be maintained with the original manufacturer labelling intact. Decanting bleach powder into an unmarked jar breaks this rule.
• All bottles containing poisonous or corrosive substances must be additionally and distinctly marked as such.
• Those bottles must be stored in an area not open or available to the public.

5. Applying It at the Station

• Never mix product outside the dispensing area. Colour, lightener, perm solution, relaxer and acrylic monomer are all mixed in the ventilated dispensary.
• Keep original labels legible. If a label becomes damaged, replace the container or re-label it with the full manufacturer information.
• Decant nothing into a food or drink container. This is where § 160.26 and § 160.23 reinforce each other.
• Store acetone, alcohol-based products and aerosols in the metal cabinet, away from electrical devices, hot tools and any flame.
• Know where the SDS binder or tablet is before you need it. In an eye splash or an inhalation incident, Section 4 gives the first-aid measures and Section 8 gives the exposure controls; both need to be reachable in seconds.
• Dispose of chemical waste correctly. SDS Section 13 governs disposal, and hazardous salon waste may not simply be poured down a drain where local rules prohibit it.