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Adam Crowell Feb 23, 2022 3 min read

Use the Proper Cleaning Agents to Combat COVID-19 and Don’t Forget the Safety Data Sheets

In conducting recent facility inspections and independently verifying the COVID-19 countermeasures that dealerships have enacted, we see hand-sanitizer everywhere.  On the Parts Counter.  On the Service Counter.  In stand-alone dispensers in the Showroom.  And work stations are commonly littered with bottles of disinfectant.

The right hand-sanitizers and disinfectants can be very effective in combating COVID-19, but when it comes to regularly cleaning your hands, the Center for Disease Control (CDC) suggests that people wash for at least 20 seconds with soap and water, and only when soap and water are not available, that people use hand-sanitizer with at least 60% alcohol.  The reasons relate to how the virus that causes COVID-19 is structured.  The outer-layer of the virus that bonds to human cells is a fatty (lipid) layer.  Soap dissolves this fatty layer and essentially inactivates the virus because the virus can no longer form a bond to human cells.  Further, when the soap is lathered, the virus becomes trapped in the suds and bubbles, and when the soap is rinsed down a drain, so too is the virus.

When alcohol-based sanitizers with at least 60% alcohol comes into direct contact with the virus, it is an effective means of killing the virus.  However, when alcohol-based sanitizers are used, it is “rubbed-in” and not “washed away,” so the virus sticks around with a chance of survival.

A list of disinfectants that can be used to combat COVID-19 on object surfaces can be found on the United States Environmental Protection Agency’s website at https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2.  Make sure you use disinfectants that are appropriate for that particular surface.  Too harsh of chemicals on metal surfaces like handrails can cause damage.  The CDC states that a bleach solution mix is also a cleaning option, consisting of either:  5 tablespoons (1/3 cup) bleach per gallon of water; or 4 teaspoons bleach per quarter of water.  Alcohol solutions that are used on surfaces should have at least 70% alcohol, according to the CDC.

With the introduction of these new chemicals into the dealership and/or with some employees now being directed to use these hazardous chemicals on a regular basis, do not forget the dealership’s obligation to adhere to the Occupational Safety and Health Administration’s Hazards Communication Standard, 29 CFR 1910.1200, which is also know as the “Right-To-Know” standard.  Under the Hazard Communication Standard, among other things, workers have a right to know about the hazardous chemicals that they are routinely exposed to in the workplace, a right to know about the measures that workers can take to protect themselves from hazards (such as, procedures, practices, and personal protective equipment (PPE)), and a right to know where Safety Data Sheets for chemicals are stored and how to read and understand the Safety Data Sheets.

Do not be lulled into thinking that complying at this time is not important, and that OSHA is not conducting inspections.   Throughout March 2020, OSHA has been actively inspecting auto dealerships and service centers.  Some of those inspections were due to “health” complaints that were initiated by employees.  Also, with the recent passage of the economic stimulus package, which provides additional funds to the Department of Labor for distribution to OSHA for the enforcement of worker safety laws and regulations, along with fewer businesses to inspect due to the “shelter in place” order, the chances of OSHA inspecting an essential business where there is a low risk of contracting COVID-19, like a dealership, could be very appetizing.

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Adam Crowell

Adam is a partner at ComplyNet and a licensed practicing attorney with over 20 years of experience primarily representing dealerships, trucking companies, and auto auctions. His experience is that most regulatory fines and lawsuits are avoidable, but it takes proactive steps, the guidance of knowledgeable experts, and great systems to effectively mitigate these risks. Adam’s first-hand experience is that a company’s compliance efforts can be leveraged for significant insurance savings, and potentially used to win other business. Prior to joining ComplyNet, Adam served as general counsel to a data management company that provides information safeguarding and custom workflow solutions to the automotive industry. Adam has spoken on the local, state, and national levels, including presentations to the National Automobile Dealers Association (NADA), the National Independent Auto Dealers Association (NIADA), and the National Association of Dealer Counsel (NADC). Adam double majored in Economics and Religion at Denison University, and was elected into the honorary Order of the Curia for outstanding academics, character, and achievements at Capital University Law School