Many employees in the graphic communications industry can be exposed to a variety of
chemicals during the course of their jobs. Since most of these employees will consume food and beverages during the work day, the possibility exists that they could contaminate their food and drinks with chemicals. Because of the potential health hazards associated with such contamination, employers are advised to implement a personal hygiene policy for employees who work with or around chemicals or other potentially harmful substances such as oil, grease, metal cuttings, etc. The policy should instruct employees to wash their hands with soap and warm water at various times during the work day to eliminate or reduce any potential contamination.
For example, employees should wash their hands:
- If chemicals, inks, oils, grease, etc., come into contact with their skin and hands
- Before taking a break to smoke a cigarette, eat, or drink
- Before using a restroom and immediately afterwards
- Immediately after removing hand protection (e.g., gloves or barrier creams) regardless of whether they were worn in conjunction with using chemicals
- Before removing/applying contact lenses or makeup
- At the end of their shifts and/or before going home
The Occupational Safety and Health Administration (OSHA) hazard communication and personal protective equipment (PPE) standards give the legal basis for employers to implement and enforce a hand-washing policy. Under the hazard communication standard 29 CFR 1910.1200 (h)(3)(iii), employers may implement specific procedures “to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and PPE to be used.” Under the PPE standard (1910.132(f)(1)(iii)), employers must train employees on the proper doffing (removal) procedures for personal protective equipment such as gloves. Hand washing is typically done at the end of a doffing procedure. Prior to washing with soap and water, it is recommended that a hand cleaner, specifically formulated for the ink/chemical system, be used for maximum effectiveness.
Proper Hand-Washing Procedures
The Centers for Disease Control (CDC) recommends the following hand-washing guidelines:
- Hands should be washed using soap and warm, running water.
- Hands should be rubbed vigorously during washing for at least 20 seconds with special attention paid to the backs of the hands, wrists, between the fingers and under the fingernails (insure that any residue is gone).
- Hands should be rinse well while leaving the water running.
- With the water running, hands should be dried with a single-use towel.
- Turn off the water using a paper towel, covering washed hands to prevent re-contamination.
Other considerations (not from CDC):
- Artificial nails can attract germs and absorb chemicals, so take extra care to clean hands properly if you wear them.*
- Keep your hands away from your face.*
- Use liquid soap in disposable containers if possible. Reusable containers should be washed and dried before refilling. Bar soap should be set on a rack to drain and dry between uses.*
- Wash hands immediately, or as soon as feasible, after removing gloves or other PPE. Ensure that proper hand cleaners are used.
- Never wash or decontaminate disposable gloves for reuse.
- See your Material Safety Data Sheets (MSDSs) for possible further hand washing recommendations and ask your supplier. For example, the supplier may suggest using cold water when washing off adhesives.
- Post hand-washing procedures in appropriate areas (e.g., work areas, break areas, rest rooms, above sinks).
- Provide periodic refresher training on the topic and include training in new employee orientation.
Eating and Drinking in Production Areas While Operating Equipment
Some printing companies have equipment which may be economically prohibitive for them to shut down during rest or meal breaks. These firms may then allow employees to eat and drink near their work station while the equipment is running. If this is done, employees must eat and drink in specifically designated areas (such as on specified tables that are not used for production activities) and utilize the hand-washing requirements before eating, drinking, and using the restroom.
OSHA standard 29 CFR 1910.141(g)(2), which applies to general industry, including printers, prohibits the consumption of food and beverages in a restroom or areas where there is possible exposure to toxic materials. OSHA currently does not offer a lot of guidance on this topic but has said the following in an interpretation letter regarding a nurse’s station:
The employer must evaluate the workplace to determine in which locations food or beverages may potentially become contaminated and must prohibit employees from eating or drinking in those areas. An employer may determine that a particular … station or other location is separated from work areas subject to contamination and therefore is so situated that it is not reasonable under the circumstances to anticipate that occupational exposure through the contamination of food and beverages or their containers is likely. The employer may allow employees to consume food and beverages in that area, although no OSHA standard specifically requires that an employer permit this. (May 17, 2006)
OSHA defines a toxic material as any substance that is present in a concentration or amount that would exceed an established threshold such as a Permissible Exposure Limit (PEL) or would have a toxicity that constitutes a recognized hazard which can cause or could cause serious injury or death.
Under certain OSHA regulations regarding exposure to toxic substances, the consumption of food and beverages is strictly prohibited. A few of these regulations which may be applicable to the printing industry include the following:
- Asbestos, 1910.1001(i)(3)(iii). The employer shall ensure that employees who work in areas where their airborne exposure is above the PEL and/or excursion limit wash their hands and faces prior to eating, drinking, or smoking.
- Lead, 1910.1025(i)(1). The employer shall assure that in areas where employees are exposed to lead above the PEL, without regard to the use of respirators, food or beverage is not present or consumed, tobacco products are not present or used, and cosmetics are not applied.
- Chromium, 1910.1026(i)(3)(ii). The employer shall ensure that employees who have skin contact with chromium wash their hands and faces at the end of the work shift and prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet.
OSHA allows for the employer to evaluate the workplace to determine in which locations food or beverages may potentially become contaminated and must prohibit employees from eating or drinking in those areas. Below are guidelines for drinking and eating in production areas:
- Identify the specific work stations and/or work areas where toxic chemicals are used. If the label on the chemical container has a “2” or higher in the blue health section, consider the chemicals to be toxic. Include areas that use the following chemicals (note, this is not an all-inclusive list):
- Prepress chemistry
- CTP developer and developer/replenisher
- Gum arabic
- Analog plate developer
- Film developer and fixer
- Chromium-based cleaners
- Film cleaners
- Lead type melting
- Acid etching of plates
- Plate processing chemicals
- Press cleaning solutions
- Blanket washes, roller washes, meter roller cleaners, chrome roller cleaners, UV coating cleaner, screen cleaning products, printers alcohol, etc.
- Fountain solution chemistry
- Alcohol substitutes
- Fountain concentrates
- Non-piling additives
- Printing Inks
- Solvent-based inks
- UV/EB-curable inks
- Vegetable-based inks
- Plastisol inks
- Aqueous-based inks
- Aerosol-based products
- Platen adhesive for textile printing
- Maintenance chemicals
- Postpress and bindery chemicals
- Liquid adhesives and glues
- Cleaning solvents
- Solvent-based ink mailing units
- Shipping/Receiving chemicals
- Sulfuric acid during battery maintenance
- Hazardous waste
- Prepress chemistry
- Identify areas near the operators’ workstations where contamination from toxic chemicals under normal circumstances is not reasonable. These areas are where employees should be allowed to eat and drink.
Also, OSHA standard 1910.141(g)(4) prohibits food or beverages from being stored in an area exposed to a toxic material. Microwaves, toaster ovens, and refrigerators should not be located in production areas. However, if these items are in the production area, they should not be stored adjacent to or near toxic chemicals or work areas were toxic chemicals are used.
Further, federal wage/hour law requires that this type of meal/break time is paid time since the employee is not completely relieved from duty (29 CFR 785.19). While federal law does not require breaks, many states regulate rest (https://www.dol.gov/whd/state/rest.htm) and meal (https://www.dol.gov/whd/state/meal.htm) periods, although most provide exceptions if the employee cannot leave the work area or duty. A few cities and counties in the country also regulate this area. Employers are encouraged to seek out their state and local rules for more information.
* Source: SafetyXChange.org
Printing Industries of America
Specialty Graphic Imaging Association
Flexographic Technical Association
Gravure Association of America, Inc.