3.4 OSHA Hazard Communication & Lockout/Tagout (LOTO) Basics

OSHA Hazard Communication (HazCom)

The OSHA Hazard Communication Standard (HazCom), often referred to as HCS, is one of the most critical safety regulations in the modern workplace. It is built on a fundamental, unyielding principle: employees have the absolute "Right-to-Know" about the identities and the physical and health hazards of the chemicals they are exposed to while performing their jobs. For custodians, who handle, mix, and apply a myriad of cleaning agents, heavy-duty disinfectants, floor strippers, and solvents daily, a thorough understanding of HazCom is a vital safety framework that prevents acute poisonings and chronic health issues.

The Right-to-Know Principle in Practice

The HazCom standard ensures that vital information about chemical hazards and the associated protective measures is effectively disseminated to all workers. Employers are legally obligated to maintain a comprehensive Hazard Communication Program, which is achieved through three primary pillars:

1. Chemical Inventory: The facility must maintain a complete, up-to-date master list of all hazardous chemicals present in the workplace. If a chemical is on the premises, it must be on this list.
2. Safety Data Sheets (SDS): Formerly known as Material Safety Data Sheets (MSDS), an SDS is a detailed, standardized 16-section document provided by the chemical manufacturer. It describes the physical properties, health hazards, safe handling procedures, required PPE, and emergency response protocols (like first aid and spill cleanup) for the chemical. Custodians must know exactly where the SDS binder or digital database is located and have unrestricted access to it during their shift. You should always review the SDS before using a new or unfamiliar chemical.
3. Comprehensive Labeling: Warning labels on chemical containers provide immediate, easily digestible hazard information. Under the Globally Harmonized System (GHS), labels must include specific pictograms (like a flame for flammables or a skull and crossbones for acute toxicity), a signal word (like "Danger" or "Warning"), hazard statements, and precautionary statements.

Secondary Container Labeling Rules

Custodians frequently buy chemicals in large bulk quantities (like 55-gallon drums) and transfer them into smaller vessels for daily use, such as hand-held spray bottles, mop buckets, or pump sprayers. These smaller vessels are referred to as "secondary containers."

• Mandatory Labeling: OSHA strictly requires that any secondary container must be clearly labeled. The label must include, at a minimum, the specific identity of the hazardous chemical matching the SDS, and appropriate hazard warnings regarding its physical and health effects.
• The Immediate Use Exception: The only exception to this rigorous labeling rule is if the secondary container is under the exclusive, continuous control of the person who transferred the chemical, AND the chemical will be entirely used or properly disposed of within that specific person's work shift. However, best practice and many facility policies dictate that all secondary containers should be labeled without exception. This eliminates the possibility of accidental misuse if the container is temporarily set down. Never, under any circumstances, leave an unlabeled secondary container unattended. A clear liquid in an unlabeled spray bottle could be water, or it could be a corrosive acid; the next person to pick it up will not know.

Lockout/Tagout (LOTO) Basics

Lockout/Tagout (LOTO) refers to specific, rigorous practices and procedures designed to safeguard employees from the unexpected startup of machinery and equipment, or the sudden release of hazardous energy, during service or maintenance activities. While custodians are generally not heavy machinery mechanics, they routinely interact with powerful equipment like industrial ride-on floor scrubbers, high-speed buffers, and heavy-duty trash compactors. Understanding LOTO is essential to avoid catastrophic injury.

Understanding Hazardous Energy

Energy takes many forms, and machines store energy even when turned off. Hazardous energy can be electrical, mechanical (moving parts), hydraulic (pressurized fluids), pneumatic (compressed air), chemical, or thermal (extreme heat). For example, if an automatic floor scrubber is turned off but the heavy rotating pad assembly is still suspended and under spring tension, that mechanical energy can cause severe crushing injuries if released unexpectedly while a custodian is reaching underneath to change the pad.

General LOTO Procedures

While authorized mechanics perform complex LOTO, custodians must understand the basic sequence to ensure they do not interfere with safety procedures:

1. Preparation and Notification: Identify all sources of energy for the equipment and notify affected employees that maintenance is beginning.
2. Shutdown: Turn off the equipment using normal operating controls.
3. Isolation: Physically disconnect the equipment from all energy sources. For most basic custodial equipment, this simply means unplugging the power cord from the wall outlet.
4. Lockout/Tagout Device Application: Apply a physical, keyed padlock to the energy isolation device. For a plug, a lockout box is placed over the plug, and a padlock secures the box closed, making it physically impossible to plug the machine in. A standardized tag is attached detailing who applied the lock, the date, and the reason. Only the person who applied the lock has the key.
5. Stored Energy Release: Dissipate or physically restrain any stored energy. This might mean waiting for spinning buffer pads to come to a complete halt, or using blocks to support heavy parts that could fall.
6. Verification: Double-check that the equipment is completely de-energized by attempting to turn it on with the normal controls before starting the maintenance work. If it doesn't turn on, it is safe to service.

Authorized vs. Affected Employees

OSHA makes a critical distinction between two types of employees regarding LOTO procedures:

• Authorized Employees: These are the highly trained individuals who actually apply the physical locks and tags and perform the maintenance or servicing on the equipment. (e.g., a facility maintenance technician repairing the electrical wiring on a trash compactor).
• Affected Employees: These are employees whose job requires them to operate the equipment being serviced, or who work in the immediate area where the servicing is taking place. (e.g., the custodian waiting to use the compactor to dispose of trash).

Critical Life-Saving Rule for Affected Employees: As an affected employee, you must never attempt to start equipment that is locked or tagged out. More importantly, you must never attempt to remove, bypass, or tamper with a lockout device applied by someone else, even if you think the work is finished. Doing so can result in immediate, fatal injuries to the authorized employee who is actively working inside the machinery. Always wait for the authorized employee to officially remove their lock and notify you that the equipment is safe to operate.