Hand sanitisers and the legal requirements

We have all gone to the shops, workplaces, our children’s school in the past few months. We have all had to sanitise our hands before entering these premises. How often have you had your hands sprayed with a hand sanitiser that was in an unmarked spray bottle? Almost always I am sure. This is however a Criminal Offence in terms of the Occupational Health and Safety Act No. 85 of 1993 - Hazardous Chemical Substances Regulations, 1995, Clause 16.

As stated in the Occupational Health and Safety Act No. 85 of 1993:

 8.        General duties of employers to their employees

(1)      Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees.

(2)      Without derogating from the generality of an employer's duties under subsection (1), the matters to which those duties refer include in particular-

(a)       the provision and maintenance of systems of work, plant and machinery that, as far as is reasonably practicable, are safe and without risks to health;

(b)       taking such steps as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment;

 What are the possible risks to using hand sanitisers?

 1.      It may increase your risk of dermatitis (a medical condition in which the skin becomes red, swollen, and sore, sometimes with small blisters, resulting from direct irritation of the skin by an external agent or an allergic reaction to it.)

 To prevent the spread of the coronavirus, the CDC recommends washing hands often with soap and water for at least 20 seconds or, if they are not available, using a hand sanitiser that contains at least 60% alcohol. Following that advice is essential, but "increased contact with chemical irritants and allergens may increase the risk of hand dermatitis or a type of eczema.

 Solution: Using a moisturiser, ideally containing mineral oil or petrolatum, may help prevent hand dermatitis. While moisturiser should be applied immediately after hand washing, this is not the case when using a hand sanitiser. Individuals should rub their hands together for about 15-30 seconds covering all surfaces with hand sanitiser until the hands are dry, and then apply a moisturiser.

 2.      May lead to skin irritation:

Hand sanitisers are antiseptic products and formulated to disinfect the skin. The primary disinfecting ingredient in hand sanitiser formulas is ethyl or isopropyl alcohol, and they are formulated along with thickeners, softeners and sometimes fragrances to curtail the strong smell of alcohol. Frequent use of it can cause skin irritation or dry out the skin. If you have sensitive skin, the effects can be worse. The drying out is caused by alcohol. If you cannot minimise your hand sanitiser use, a good idea is to follow up with a moisturising regimen.

 3.             Some formulations may adversely affect health

Some non-alcohol-based hand sanitisers that consist of an antibiotic compound called triclosan or triclocarban has shown in studies to be a health hazard as its overuse has negative effects on the body’s immune system.

 4.             You may be prone to getting a skin disorder

The overuse of alcohol-based hand sanitisers to safeguard against the germs and infection causing pathogens could inversely increase the risk of infection via skin disorders. Overdoing it may remove non-threatening normal skin bacteria which may result in secondary infections. 

 5.             May lead to alcohol poisoning if ingested.

Many hand sanitisers contain very high levels of alcohol and there have been various reports of people ingesting hand sanitisers and requiring medical intervention.

·        Do not drink it!

·        Keep it away from children.

·        Educate children of the possible dangers.

·        Call 084-124, 082 911 or 112 immediately if you or someone else has swallowed hand sanitiser.

 We need to however ensure the safety of our staff, clients, and others. With the understanding of the below legislation we can easily comply and ensure the people on our property are safety.

 Occupational Health and Safety Act No. 85 of 1993 - Hazardous Chemical Substances Regulations, 1995 defines a “hazardous chemical substance” as follows: means any toxic, harmful, corrosive, irritant or asphyxiant substance, or a mixture of such substances for which—

(a) an occupational exposure limit is prescribed; or

(b) an occupational exposure limit is not prescribed, but which creates a hazard to health;

 Extreme cautions are to be taken when handling, storing, transporting, and using hazardous chemicals. The user needs to wear protective clothing and personal protective equipment to protect themselves from hazardous chemicals. Depending on the chemicals, this might involve rubber gloves, safety goggles, chemical-resistant coveralls, or respirators.

Hazardous chemicals are accompanied by Material Safety Data Sheets (MSDS) that outlines the severity of the potential risks as well as the safety measures that must be in place when handling these substances.

 Handling of hazardous chemical substances

9A (1) Subject to section 10(3) of the Act, every person who manufactures, imports, sells or supplies any hazardous chemical substance for use at work, shall, as far as is reasonably practicable, provide the person receiving such substance, free of charge, with a material safety data sheet in the form of Annexure 1, containing all the information as contemplated in either ISO 1 1014 or ANSIZ400.1.1993 with regard to-

(a) product and company identification;

(b) composition/information on ingredients;

(c) hazards identification;

(d) first-aid measures;

(e) fire-fighting measures;

(f) accidental release measures;

(g) handling and storage;

(h) exposure control/personal protection;

(i) physical and chemical properties;

(j) stability and reactivity;

(k) toxicological information;

(l) ecological information;

(m) disposal considerations;

(n) transport information;

(o) regulatory information; and

(p) other information:

Provided that, where it is not reasonably practicable to provide a material safety data sheet, the manufacturer, importer, seller or supplier shall supply the receiver of any hazardous chemical substance with sufficient information to enable the user to take the necessary measures as regards the protection of health and safety.

(2) Every employer who uses any hazardous chemical substance at work, shall be in possession of a copy of Annexure 8 or a copy of sufficient information, as contemplated in subregulation (1).

Check your company’s hand sanitisers MSDS and carefully read the fire safety and first aid precautions.

Many hand sanitisers have a very low fire flash point, some as low as 22 degree Celsius. (Flash point is the lowest temperature at which a liquid can gives off vapour to form an ignitable mixture in air near the surface of the liquid. The lower the flash point, the easier it is to ignite the material.)

Thus, it should not be kept in the direct sun or in a car where vapour may come close to a heat source.

General first aid for accidental poisoning or ingestion of hand sanitiser

Labelling, packaging, transportation, and storage

 14. An employer shall, in order to avoid the spread of contamination of an HCS, take steps, as far as is reasonably practicable, to ensure:

(a) that the HCS in storage or distributed are property identified, classified and handled in accordance with SABS 072 and SABS 0228;

(b) that a container or a vehicle in which an HCS is transported is clearly identified, classified, and packed in accordance with SABS 0228 and SABS 0229; and

(c) that any container into which an HCS is decanted, is clearly labelled with regard to the contents thereof.

For the complete Hazardous Chemical Substances Regulations, 1995

Hand sanitisers are a good alternative to reduce potentially infectious microbial loads such as viruses, bacteria, fungus on your hands or skin, if soap and water are not immediately available. Hand sanitisers do not remove physical dirt, grime, mucus etc. A hand sanitiser is therefore not as good as soap and water.

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