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Definition of Hazardous Chemicals - what chemicals and substances fall under 11.6.4

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Posted 15 March 2022 - 07:24 PM

I am putting together our Chemical and SDS Audit for our facility, and I was going to add the section 11.6.4 about Storage of Hazardous Chemicals and Toxic Substances, but I'm trying to figure out the exact definition of a Hazardous chemical. 


I found something from OSHA which states "A hazardous chemical, as defined by the Hazard Communication Standard (HCS), is any chemical which can cause a physical or a health hazard". 


Cutting to the chase, I'm trying to figure out what chemicals/substances which fall under 11.6.4. From my understanding, according to OSHA's definition, any chemical which has any warning category for Toxicity or Hazardous Material falls under 11.6.4. For example, we use 70% EtOH in spray bottles on our bottling lines. This chemical is Category 2 Flammable, Category 1/2 Toxicity. Do we have to lock up the spray bottles when they are not in use, or can they remain on the line and be locked up at the end of the day? 


Our production facility contains a Warehouse, a Cellar and Bottling Line. Can we have different chemical storage areas for each part of our facility? 




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Posted 15 March 2022 - 08:12 PM

You are allowed to have "day use" chemicals not locked up.   For instance, a small contaner that dispenses soap or sanitizer in a three compartment sink would not need to be locked up.   Your spray bottles if used throughout the day during operation would not need to be locked up. Locking them up at the end of the day would be fine in this case.  The goal is limit access but not create a burden for operating properly.   


You can have more than one chemical storage area.   Some have numerous lockable "huts" placed through out facilities.   




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