Infection Control Today - 08/2000: Safety First: Read, Heed Labels

Safety First: Read, Heed Labels
Cleaning Product Labels Are More than Just Words

By Janet B. Kreizman

The role of manufactured cleaning products and disinfectants in controlling andpreventing the spread of communicable diseases is well documented. Whether in healthcaresettings such as hospitals, nursing homes, and surgi-care centers or in privatehouseholds, products that fight harmful bacteria, including waterborne pathogens, viruses,and other microorganisms that serve a fundamental function in protecting public health.Healthcare settings, of course, require higher performance products and procedures tocombat the great variety of pathogens that might contaminate equipment and other surfaces.This antimicrobial cleaning performance is critical to protect patient and staff healthand prevent nosocomial infections, which can prolong hospital stays and increase the costof patient care.

Products purchased for healthcare use often are packaged as concentrates in largesizes, require mixing (either by staff or automatic proportioning devices), and maynecessitate more frequent handling than household cleaners. These conditions add to theneed for safe and proper handling of healthcare products to ensure both the product'sefficacy and staff safety.

Given the importance of safe and proper product use, clear guidelines are critical.Cleaning product labels are the guidelines for the optimal and safe use ofproducts--whether used in the home or in healthcare settings. The information included isregulated and monitored by various federal and state agencies, including the EnvironmentalProtection Agency, the Consumer Product Safety Commission, and the Federal TradeCommission. But long before the label is printed and placed on the product container,manufacturers consider the product's purpose, how it will be used, and the chemicalsinvolved to assess health and safety risks. Thus, they can manufacture products that willperform as indicated, when used as directed, and can be used safely. Product manufacturersmeet--and often exceed--federal label requirements, so they can ensure that labelscommunicate clearly what is known about the product's benefits and risks.

The risks assessed include oral, skin, and inhalation acute toxicity; primary eye andskin irritation; flashpoint for flammable materials (solids, liquids, and aerosols); andchronic toxicity (carcinogenicity, neurotoxicity, and reproductive toxicity).Manufacturers perform these assessments to determine the label content and format,including precautionary label text, to protect consumers and children. Federal HazardousSubstance Act regulations provide manufacturers with specific guidelines to determinepotential risks specific to a product's formulation and packaging. At a minimum, labelsmust include:

• Hazard signal word

• Affirmative statement of hazard(s) associated with the product

• The name of each component that contributes to the hazard

• Precautionary measures to be taken to avoid risk

• Required or appropriate instruction for first aid treatment

• Appropriate handling instructions

• Appropriate storage instructions

• The statement, "Keep Out of Reach of Children" or its equivalent¹

Because consumers have a wide variance of understanding, language, and reading skills,the federal government and some state governments require that certain parts of the labelbe uniform in format and terminology. This standardized use reinforces recognition ofcertain phrases among consumers to minimize misuse. The signal words caution, warning,and danger are examples of such standardized language. These words denote, aslisted, an increasing level of risk associated with product use, i.e., cautionindicates a lesser degree of risk than warning. Signal words are followed by a statementidentifying the specific hazard, such as, harmful if swallowed.

This information--signal words, chemical names, first-aid instructions--may appearforeboding; however, the purpose of labels is just the opposite. Warning words and stronglabel messages are designed to get the consumer's attention, encourage respect forchemical products, and prescribe safe and effective product use.

In healthcare settings, labels are one component of proper product use management. On abroader level, safe and effective product use in institutions is a partnership betweenmanufacturers and employers as well as employees responsible for using the product inaccordance with prescribed guidelines and training by informing management when employeesdo not understand how to use the product safely and effectively.

The Occupational Safety and Health Administration (OSHA) has established acomprehensive hazard communications program "to ensure that the hazards of allchemicals produced or imported are evaluated, and that information concerning theirhazards is transmitted to employers and employees."² The program outlinesspecific and extensive responsibilities for manufacturers and employers and requirestraining and communication among manufacturers, employers, and employees to be effective.Manufacturers can assist employers with developing and reinforcing appropriate training.

Following OSHA-specified guidelines, manufacturers are responsible for evaluating theindividual chemicals they produce to determine potential physical and health risks as wellas determining hazards associated with mixtures that contain more than one chemical.Responsibilities also include ensuring that the product is properly labeled, tagged, ormarked with the identity of the hazardous chemical, appropriate hazard warnings, andmanufacturer contact information.

Manufacturers also are required to develop a material safety data sheet (MSDS) for eachhazardous chemical they produce.

The MSDS provides in-depth information about the chemical substances workers handle.For example, the MSDS must reveal chemical and common names of single-substance chemicals;a list of ingredients that contribute to known hazards for mixtures; physical and chemicalcharacteristics of the hazardous chemical; physical and health hazards associated with thechemical; any generally applicable precautions; control measures; and emergency and firstaid procedures.

Employers are required to ensure that they have an MSDS for all chemicals and chemicalmixtures received from the manufacturer and that each container of hazardous chemicals islabeled with the identity of the hazardous chemicals and appropriate hazard warnings.Employers also are required to develop, implement, and maintain a written hazardcommunication program. Written materials must be readily accessible to employees in theirwork area, and labels and other forms of warnings must be legible in English and any otherlanguage necessitated by the workforce. Employers also must provide initial and ongoingemployee training on hazardous chemicals in the work area.

Hospitals and other healthcare facilities require powerful products to ensure thatsterile environments are maintained and that patient and staff health is protected frominfectious agents. These products contain chemicals that must be handled precisely andwith care to ensure both the product's efficacy and staff and patient safety. Federalregulations govern label content for home and institutional products, and in addition,have formalized training and other guidelines to protect institutional users of cleaningproducts. Manufacturers develop products with end-use and safety considerations in mind.Labels are more than words. On home or healthcare products, they are important guides forproper and safe product use. They should not be overlooked nor ignored.

Janet B. Kreizman is the executive director for the Alliance for Consumer Education(ACE), a non-profit, public charity founded to promote the safety, health, and well-beingof individuals, wherever household and institutional products are used. Through, ACE sheworks with consumers, environmental groups, the media, and policymakers at all levels ofgovernment to provide the most current, accurate, science-based information on the properand safe use, storage, and disposal of household and institutional products and theirvital contribution to personal and public health.

^1. Consumer Product Safety Commission, Federal Hazards Substances Act, 16CFR1500.121 (Code of Federal Regulation).
^2. Occupational Safety and Health Administration Regulations, Hazard Communications, Toxic, and Hazardous Substances, 29CFR1910.1200.

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