ISSA Discourages EPA from Imposing Redundant Training Requirements
While ISSA places a high value on employee training for all members of the cleaning industry, the Association filed comments opposing EPA’s contemplated training for employees who apply antimicrobial pesticides, such as sanitizers, in institutional settings as being redundant and duplicative of existing training regulations established by OSHA and other agencies, according to a recent ISSAlert.
EPA recently formed a work group for the purpose of ramping up the Agency’s current training regulations. As part of this process, EPA has made it clear that it is considering the imposition of new training regulations for those employees (such as janitors, building service contractors, custodians, etc.) who, as part of their job, apply disinfectants, sanitizers, and other antimicrobial pesticides.
ISSA agrees that such employees require training, however, ISSA director of legislative affairs Bill Balek pointed out that comprehensive federal requirements for employee training in such situations already exist, and provide ample protection for the safety and health of workers who apply disinfectants, sanitizers, and other antimicrobials in institutional and industrial facilities.
Specifically ISSA alluded to protections provided by the OSHA Hazard Communication Standard that establishes an extensive regulatory scheme designed to protect employees who use chemical products (including disinfectants and sanitizers) that relies on labeling, material safety data sheets (MSDS), written hazard communication programs, as well as employee education and training.
“Any additional training,” stated Balek, “such as that contemplated by EPA, would be duplicative of existing law, and therefore provide no significant benefit to employees but would only serve to place another unreasonable burden on employers.”
In its comments, ISSA also noted that industry outreach efforts are on the rise, such as the ISSA/OSHA Alliance, the principal purpose of which is to provide employers with information, guidance, and access to training resources that will help protect employees’ health and safety. For example, ISSA and OSHA are working to develop education and training programs for cleaning and maintenance industry employers and employees in the area of hazard communication including the safe use of chemical cleaning products.
ISSA further pointed out that EPA has failed to establish a rational basis that would justify the additional, redundant training contemplated by the Agency, especially in light of the extensive existing federal training regulations and industry outreach efforts. In fact, statistics compiled by the Bureau of Labor Statistics indicate that the number of occupational injuries and illnesses due to disinfectant exposure have declined significantly in recent years.
ISSA will continue to participate in a series of EPA-hosted conferences that will focus on the issue of training for employees who apply antimicrobials, and which will be conducted through the end of the year.
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