3.5 Chemical Safety: Labeling and Storage, Safety Data Sheets, Federal Agencies, Adverse Reactions, and Ventilation

Why this topic matters

The "Workplace Safety Precautions" half of Domain I (24 percent) includes five chemical subtopics: labeling and storage of materials and chemicals; Safety Data Sheets and prohibited materials; federal safety regulations (OSHA, EPA, FDA); identifying adverse reactions to chemicals; and proper ventilation. The practical test also scores chemical safety: products that belong on an SDS must be in original manufacturer-labeled containers, and aerosols are not allowed.

Labeling chemicals

Under OSHA's Hazard Communication Standard (HCS), a manufacturer's label on a hazardous chemical carries six elements:

1. Product identifier (name or code)
2. Signal word: "Danger" for more severe hazards or "Warning" for less severe ones
3. Hazard statements, such as "Causes severe skin burns and eye damage"
4. Pictograms: red-bordered diamonds showing the hazard type, such as corrosion, flame, or exclamation mark
5. Precautionary statements for prevention, response, storage, and disposal
6. Name, address, and phone number of the manufacturer or importer

Rules for barbers:

• Keep original labels intact and readable. Do not peel, cover, or write over them.
• Label any secondary container. If you pour disinfectant concentrate or developer into a spray bottle, applicator bottle, or jar, label it with at least the product name and its hazards.
• Never store chemicals in food or drink containers. A clear relaxer or developer in a water bottle invites poisoning.
• Wet disinfectant jars at each station must hold properly mixed EPA-registered disinfectant (Tennessee Rule 0200-03-.08). Many barbers also mark the jar with the product and the date it was mixed.

Storing chemicals safely

Follow SDS section 7 (Handling and Storage). General rules:

• Store in a cool, dry place away from heat, sunlight, and open flames. Heat speeds the breakdown of hydrogen peroxide and can build pressure in closed containers.
• Keep lids tightly closed to stop evaporation, contamination, and fumes.
• Separate incompatible products. Keep oxidizers, such as peroxide developers and persulfate lighteners, away from flammables and reducing agents such as waving lotions. Never mix bleach with ammonia or acids, because that releases toxic gas.
• Keep flammables such as alcohol, aerosols, and some sprays away from hot tools and heaters.
• Store heavy containers low, and do not store chemicals where clients can reach them.
• Dispose of mixed chemicals and empty containers as the SDS and label direct (section 13).

Safety Data Sheets

Under 29 CFR 1910.1200, the employer must keep a Safety Data Sheet (SDS) for every hazardous chemical in the workplace. The SDS must be readily accessible to employees during every shift, and employees must be trained on the hazards and how to protect themselves. The 16 required sections are listed in the table at the end of this section.

Prohibited materials

• Tennessee Rule 0200-03-.06 bars keeping FDA-banned cosmetic ingredients on the premises, including liquid methyl methacrylate (MMA), and bars using any product in a way the FDA prohibits.
• The FDA has not approved any color additive for permanently dyeing or tinting eyebrows or eyelashes. Coal-tar hair dyes must never be used there (section 7.4).
• Lead acetate, formerly used in progressive hair color "restorers," is no longer permitted in U.S. hair dyes. The FDA's repeal of its approval took effect in January 2022.

Which federal agency does what

A common trap is mixing up OSHA and EPA. OSHA protects the worker. EPA approves the disinfectant. FDA covers the products used on the client.

Identifying adverse reactions to chemicals

What to do:

1. Stop the service at the first complaint of burning or any sign of a reaction.
2. Rinse the product off with cool (not hot) running water. For relaxer, use the neutralizing shampoo the manufacturer directs.
3. For eye splashes, flush with clean running water for 15 minutes or as the SDS first-aid section directs, and get medical care.
4. Move anyone with breathing symptoms to fresh air. Call 911 for severe swelling or difficulty breathing.
5. Document what happened and the product used, and refer the client to a physician. Do not diagnose or treat.
6. Patch-test future oxidation color services (section 7.4), and note any sensitivity on the client record.

Ventilation

Tennessee Rule 0200-03-.03 requires shops and schools to operate only in rooms that are adequately lighted and ventilated. Good ventilation practice:

• Mix chemicals in a ventilated dispensary area, not next to a client's face, and keep containers closed.
• Use local exhaust or source capture near chemical stations when possible, and keep the HVAC system running and maintained.
• Measure lightener powder gently to limit dust; dust-free formulas help.
• Limit aerosols near clients (PSI bans them from the practical exam).
• For keratin smoothing products, check the SDS for formaldehyde or methylene glycol. OSHA limits formaldehyde exposure to 0.75 ppm as an 8-hour average and 2 ppm over any 15 minutes, with extra requirements starting at a 0.5 ppm action level.

Personal protective equipment. Wear chemical-resistant gloves such as nitrile when mixing and applying chemicals, and safety glasses or goggles when splashes are possible. Tennessee requires schools to keep disposable gloves and safety goggles available to students (Rule 0200-01-.15(4)).

OSHA Hazard Communication Standard (HCS) and Safety Data Sheets

Beyond biological hazards, barbers work daily with potentially dangerous chemical substances, including chemical relaxers (sodium hydroxide), permanent wave solutions (ammonium thioglycolate), hair dyes containing phenylenediamines, developers (hydrogen peroxide), and concentrated chemical disinfectants.

The "Right-to-Know" Law

OSHA's Hazard Communication Standard (HCS) (29 CFR 1910.1200), often referred to as the employee "Right-to-Know" law, mandates that chemical manufacturers, importers, and employers evaluate chemical hazards and communicate protective information to workers.

In 2012, OSHA aligned the HCS with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS), establishing standard hazard pictograms, signal words ("Danger" for severe hazards; "Warning" for less severe hazards), and a standardized 16-section document known as the Safety Data Sheet (SDS) (formerly the Material Safety Data Sheet or MSDS).

The Standardized 16-Section SDS Structure

Every commercial chemical product entering a barbershop must be accompanied by an SDS formatted into exactly 16 uniform sections:

Barbershop Regulatory Compliance Mandates

1. Immediate Accessibility: Barbershop owners must maintain an organized physical binder or centralized digital terminal containing an SDS for every hazardous chemical present in the establishment. This library must be immediately accessible to all employees at all times during working hours, without requiring supervisor permission or password barriers.
2. Secondary Container Labeling: When bulk chemical concentrates (such as quat solutions or shampoo concentrates) are transferred into secondary dispensing containers (such as spray bottles or squeeze dispensers), the secondary container must be clearly labeled with the product's identity, key chemical components, and applicable GHS hazard warnings.
3. Staff Training: Employers must educate all barbers upon initial hire and whenever new chemical hazards are introduced into the shop, ensuring staff can interpret SDS data sheets, select appropriate PPE, and execute emergency first aid measures.