Hazard Alert: Hand Sanitizer

Potential hazards involving hand sanitizer, hand sanitizer bottles and hand sanitizer dispensers have been identified within ESDC, Service Canada and Labour Program workplaces.

Hand Sanitizer is a hazardous substance. The Hazardous Products Act and Hazardous Products Regulations consider it to contain flammable materials (alcohol). The Canada Occupational Health and Safety Regulations (COHSR) stipulates in section 10.8 that, “every hazardous substance stored, handled or used in a work place shall be stored, handled or used in a manner whereby the hazard related to that substance is reduced to a minimum”. Given this, it is important that all hazards associated with the storing, handling and use of hand sanitizer in the workplace be reduced wherever possible.

In addition, as of December 1st, 2018, there must be Workplace Hazardous Materials Information System (WHMIS) 2015 labels and Safety Data Sheets (SDS*) for all hazardous products in the workplace.

Potential Hazards and Guidance

Handling Hazards

  • Spills and Splashes

    Hand sanitizer might spill on floor or splash into an individual’s face/eyes when manually transferring from one bottle to another (e.g. when refilling a dispenser). This could cause a slippery surface and result in a fall or skin/eye irritation and damage.

    Guidance:

    When ordering hand sanitizer:

    • Order manageable bottle sizes (e.g. 1L bottles) – preferably single use bottles.
    • If ordering larger refill containers, order containers equipped with a pump. Large refill containers should not exceed 4L.

    When refilling and handling hand sanitizer bottles:

    • Where possible, do not manually transfer hand sanitizer from one bottle to another.
    • If manual transfer is required:
      • use a pump as it can help to safely transfer hand sanitizer from one bottle to another;
      • equip yourself with the appropriate personal protective equipment (PPE) (e.g. gloves and eye protection); and
      • do not carry or lift more than 23 kg.
    • If transferring a large quantity of hand sanitizer (e.g. transferring multiple bottles), make sure to take regular breaks to prevent wrist/hand strain.
  • Maintaining Dispensers

    Hand sanitizer dispenser nozzles might clog, causing hand sanitizer to splash onto unintended parts of the skin or into the eyes of an individual when the dispenser pump is pushed. This could result in skin/eye irritation and damage.

    Guidance: Perform regular maintenance on hand sanitizer dispensers as per manufacturer’s recommendations (e.g. clean dispenser nozzles regularly to prevent clogs). When doing so, make sure to equip yourself with the appropriate PPE (e.g. gloves and eye protection) and perform the maintenance in a well-ventilated area.

    In addition, ensure dispensers only hold appropriate types/brands of hand sanitizer as outlined in the manufacturer’s recommendations (e.g. liquid dispensers should only hold liquid hand sanitizer).

  • Mixing of Types/Brands

    The mixing of hand sanitizer types/brands might be occurring in some workplaces (e.g. when refilling hand sanitizer dispensers), which could result in irritation and damage to an individual’s skin when applied (due to a chemical or allergic reaction).

    Guidance: Do not mix hand sanitizer types/brands. The type/brand of hand sanitizer identified on the bottle or dispenser should be the type/brand of hand sanitizer in the bottle or dispenser.

    If pouring hand sanitizer from one bottle to another, the SDS* for the hand sanitizer must be reviewed and followed and the label on both bottles must match.

  • Placement of Bottles

    The placement of hand sanitizer bottles on inappropriate surfaces and at inappropriate heights might be occurring in some workplaces. This may cause bottles to fall or tip over when used – and hand sanitizer to spill onto the floor. This could cause a slippery surface and result in a fall.

    Guidance: Place hand sanitizer bottles on solid, flat surfaces and at heights that are appropriate for use. In addition, ensure that the hand sanitizer is stored in original containers.

  • Applying to Hands

    Some individuals in the workplace might not know how to properly apply hand sanitizer to their hands. If an individual applies hand sanitizer incorrectly, this could result in:

    • The individual transferring germs or a virus to another employee/client (e.g. If the individual does not apply the hand sanitizer to all parts of their hands.); and/or
    • An injury (e.g. If the individual applies too much hand sanitizer to their hands and some of it falls to the floor. This could create a slippery surface and cause someone to slip/fall.).

    Guidance: Ensure appropriate signage (PDF Version, 190 KB) that outlines how to properly apply hand sanitizer is placed near hand sanitizer dispensers and at locations where hand sanitizer bottles are present.

Placement Hazard

  • Dispensers/Bottles Near Heat Sources

    Hand sanitizer dispensers and bottles might be located near heat sources in some workplaces, which could result in a fire.

    Guidance: Do not place hand sanitizer dispensers and bottles near heat sources. In particular, during summer months do not place hand sanitizer dispensers and bottles in direct sunlight. Refer to the product’s SDS* for more info.

Storage Hazard

  • Large Quantities Near Heat Sources

    Large amounts of hand sanitizer could be present and located near heat sources in some workplaces, which could result in a sizeable fire.

    Guidance: If possible, consider storing hand-sanitizer at an off-site warehouse or storage facility.

    If storing hand sanitizer off-site is not possible and you are storing hand sanitizer in the workplace:

    • Ensure that the workplace is able to meet the storage and handling requirements;
    • Only order required/minimum quantities in order to limit the total quantity stored in the workplace;
    • Ensure an inventory of the volume of all hand sanitizer stored in the workplace is maintained and documented;
    • Break up the bulk quantity (>25L) into smaller groups and store in different areas throughout the workplace;
    • Do not store in the basement or in areas containing plausible sources of ignition and ensure no other substances are stored with the hand sanitizer that could react or be ignitable due to the combination; and
    • Ground floor storage is preferred as it is easier to access during an emergency.

    Contact the Chief Financial Officer Branch (CFOB) if you require storage equipment or space to safely store hand sanitizer (e.g. a storage cabinet or warehouse).

Roles and Responsibilities

  • Procurement (or Regional Management Services (RMS) in some regions) is responsible for all ordering related to hand sanitizer.
  • Site Leads (or on-site managers) are responsible for the storing, handling and use of hand sanitizer in the workplace.
  • Site Leads (or on-site managers) should consult with Workplace Health and Safety Committees and Health and Safety Representatives on all decisions related to workplace hazards, including hazards related to hand sanitizer.

Training

Employees, managers and supervisors responsible for the handling, shipping and/or receiving of hand sanitizer in the workplace must complete Workplace Hazardous Materials Information System (WHMIS) 2015 training. The Canadian Centre for Occupational Health and Safety (CCOHS) offers the following courses:

Employees, managers and supervisors responsible for shipping hand sanitizer must complete Transportation of Dangerous Goods (TDG) - Training.

Note: There is currently a certificate exempting the Transportation of Dangerous Goods - Training requirement if shipping hand sanitizer quantities of less than 30 litres. It is set to expire on December 31, 2021.

Employees, managers and supervisors responsible for the handling and/or receiving of hand sanitizer in the workplace must complete Manual Materials Handling training on Saba.

Employees, managers and supervisors responsible for the handling of hand sanitizer in the workplace must complete PPE training.

Other Considerations

Hand sanitizer in some workplaces may have expired or is close to expiring.

Expired hand sanitizer must be disposed of in accordance with local regulations.

Expired hand sanitizer may not be effective and could result in an individual transferring germs or a virus to another employee/client.

Additional Information

For additional information, contact your Regional Occupational Health and Safety Advisor (ROHSA) through the Human Resources Service Centre.

*The SDS is a document that contains information on the potential hazards of a product. It also provides guidance on how to use it safely. It must be readily available to all employees for review.