QUESTION:
My company is working out of my house. I have just started it and am wondering what kinds of labels are required if I am storing extra chemical in my garage for my technicians to use.
ANSWER:
It would be important to discuss this with your local regulatory agency and inspectors, as each state may have its own interpretations of exactly what THEY want to see in place in any office. However, it would be expected that whether it is a home office and “warehouse” or a dedicated office and warehouse in a commercial building, the requirements should be the same. Generally speaking, anyplace you store pesticides for your business uses you must have the product Labels and MSDS’s for every product kept on hand. This could include even glue traps, as these have an MSDS and therefore important information on their safe handling.
The needs for these product documents are these. First, if the unexpected emergency occurs, such as a spill or fire involving your pest control materials, both you and any emergency agency that handles the problem needs to be able to read the information regarding how to handle that product in that specific emergency. For example, in a fire will there be toxic fumes produced, or is there a chance of an explosion? What is the appropriate extinguishing medium? Is there a chance of runoff to nearby storm drains or creeks? This information is on the MSDS for each and every pesticide and miscellaneous materials such as glue boards, and without having it available the emergency response could be done incorrectly. In fact, one of the requirements for training is called Hazard Communication, an OSHA requirement and possibly also a requirement from your local regulatory agency. Haz Com training involves the Label and MSDS information on exactly this, and every employee who is in any way exposed to any pesticide product must have this training. It must be documented in writing and done annually. See our newest Master Technician course, #208 on Hazard Communication, for an in depth look at the topic.
The Labels also have some Emergency information, as well as details on Environmental or Personal hazards that could occur, and these should be part of that Haz Com training. The MSDS and Label also outline what course of action must be taken if someone or some other animal is exposed to the pesticide – got it on their skin, swallowed it, inhaled it, etc. This might be a call from a veterinarian telling you that a customer just brought their dog in because the dog ate some rodent bait placed there by your employee, and now wants to know exactly what kind of bait it was and what emergency steps he needs to take for that pet. The label and MSDS need to be on hand and available to provide to the vet. In addition to the technicians who are out applying the products, EVERY person in the office also needs to be familiar with the product documents so they know where to find them and how to access the important information.
If you store pesticides in your garage this space is now considered to be an official Pesticide Storage Area, and again it is important for you to talk with your local regulators to see what they want done here with respect to posting and signage. It is likely they will require you to place Pesticide Storage Warning Signs on the exterior of the garage to warn others of the contents within. Again, this becomes important in that emergency when emergency personnel respond and can see before they rush into the area that toxins are stored there. You may even need to talk with the local fire department on this to see if they insist on signage of their own, which might be coded letters indicating the kinds of toxins stored there.
Depending on what your local regulatory folks tell you is needed, you may need to store all the pesticides in a physically separated area within the garage, and certainly behind locked doors. You may need to have them stored over a containment setup of some sort, such as a large pan that would capture any spilled material or contain the water used to put out a fire. The goal here is to minimize the problem by keeping liquids from flowing out of the garage and into the gutter, where the next stop is the local creek, and now your liability is tremendously increased. You may need to install some venting or fans to ensure no buildup of fumes could occur in the storage area.
View past Ask Mr. Pest Control questions.
Pest QuestionsNovember 01, 2011
