The Dragons of Healthcare Workplace Safety: HCS, SDS and GHS

Understanding The Hazardous Communication Standard, Safety Data Sheets (SDS), The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and how to properly implement them to insure workplace safety and comply with OSHA.

We at HCSI train healthcare professionals and their staff members on the Federal OSHA requirements for medical providers. Even though our training covers all required areas such and The Hazard Communication Standard, Safety Data Sheets, GHS labeling rules, etc., we occasionally get a frantic call from a confused practice manager or compliance officer after a friendly visit by an OSHA inspector.  Even though they were trained on these subjects, they invariably did not take the time to implement the training and translate it into the preparation of their site specific required safety and regulatory documentation. Once again, the classic saying, perhaps older then the dragons of ancient lore, rears it's ugly head... "If it wasn't documented, it never happened."

All hazardous chemicals found in the workplace/practice must be identified and a Master List must be compiled containing the names of products, their manufacturers and their chemical components. This Master List can be compiled from information gained from a list of OSHA regulated substances such as the NIOSH Pocket Guide to Chemical Hazards.

Safety Data Sheets (SDS) [previously called Material Safety Data Sheets (MSDS) which are now obsolete and superseded by the GHS Global Harmonized Standard implemented in 2013 replacing MSDSs with SDSs] are forms generally provided by chemical manufacturers that convey hazard-related information on chemicals and hazardous substances you use in your workplace.  It is important that employees know how to interpret the information found on each SDS, which describes the chemical composition, health and physical hazards and safe handling and emergency procedures for all products containing hazardous substances. 

In the U.S., the Occupational Safety and Health Administration (OSHA) requires that SDSs be readily available to all employees for potentially harmful substances handled in the workplace under the Hazard Communication regulation. The SDSs are also required to be made available to local fire departments and local and state emergency planning officials under Section 311 of the Emergency Planning and Community Right-to-Know Act. The American Chemical Society defines Chemical Abstracts Service Registry Numbers (CAS numbers) which provide a unique number for each chemical and are also used internationally in SDSs.

In 2012, the US adopted the 16 section Safety Data Sheet to replace Material Safety Data Sheets. This became effective on December 1, 2013. These new Safety Data Sheets comply with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). By June 1, 2015, employers were required to have their workplace labeling and hazard communication programs updated as necessary – including all MSDSs replaced with SDS-formatted documents.

Many companies offer the service of collecting, or writing and revising, data sheets to ensure they are up to date and available for their subscribers or users. Some jurisdictions impose an explicit duty of care that each SDS be regularly updated, usually every three to five years. However, when new information becomes available, the SDS must be revised without delay.

Hazard Communication Standard

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.

In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable/(i.e. training provided) to workers. OSHA's Hazard Communication Standard (HCS) requires the development and dissemination of such information:

• Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers;
• All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately. 

Major changes to the Hazard Communication Standard 

• Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
• Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
• Safety Data Sheets: Will now have a specified 16-section format.
• Information and training: Employers are required to train workers on the new labels elements and safety data sheets format to facilitate recognition and understanding.

GHS Pictograms

As of June 1, 2015, the HCS requires that new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below:

Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Section 4, First-aid measures includes important symptoms/effects, acute, delayed; required treatment.

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.

Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); ACGIH Threshold Limit Values (TLVs); and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS where available as well as appropriate engineering controls; personal protective equipment (PPE).

Section 9, Physical and chemical properties lists the chemical's characteristics.

Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.

Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12, Ecological information*

Section 13, Disposal considerations*

Section 14, Transport information*

Section 15, Regulatory information*

Section 16, Other information, includes the date of preparation or last revision.

*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

Employers, please remember to periodically review and update your hazardous substance/chemicals Master List and ensure your SDSs reflect those changes and are readily accessible, readable and also understandable to your employees as well as any fire department personnel, inspectors and/or government officials. Annual OSHA training is also required to ensure your staff is educated, aware and updated on these and other vital workplace safety issues.

Protecting your employees, patients and your office's regulatory reputation is an ongoing process requiring diligence and oversight. You can not simply take an apprentice course in the basics of fending off dragons in the hopes of never encountering one of the dreaded beasts. The knighthood of compliance (OSHA or otherwise) requires the quest of discovering your office's site specific situations, knowing your procedures along with the discipline of documentation and the situational awareness to defend against the dragons of workplace safety and regulatory compliance. 

Source(s): https://www.hcsiinc.com, https://www.cdc.gov/niosh/npg/, https://www.osha.gov/dsg/hazcom, https://en.wikipedia.org/

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Five Areas that Require Bio-hazard Labeling

The Bloodborne Pathogens Standard outlines the regulations for bio-hazard labeling and color-coding. Three signals can alert you to the presence of a bio-hazard or bio-hazardous waste: the word “bio-hazard”, the bio-hazard symbol, or the fluorescent orange or orange-red color-coding.

These five areas are ones to watch for bio-hazard labeling in your facility:

1. Regulated medical waste containers and other containers (according to OSHA) that warning labels must be affixed to:

• Containers of regulated waste,
• Refrigerators and freezers containing blood or other potentially infectious material; and
• Other containers used to store, transport or ship blood or other potentially infectious materials.

EXCEPTIONS include:

• Containers of blood, blood components, or blood products that are labeled and have been released for transfusion,
• Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal, or
• Regulated waste that has been decontaminated.

2. Sharps Containers

Sharps containers must also be labeled or color-coded in accordance with the requirements of the Bloodborne Pathogens Standard.

3. Contaminated Laundry

The Bloodborne Pathogens Standard also requires contaminated laundry to be placed and transported in labeled or color-coded bags. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.

When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in labeled or color-coded bags or containers.

4. Specimens

Specimens of blood or other potentially infectious materials must be placed in a container which prevents leakage during collection, handling, processing, storage, transport, or shipping. The container for storage, transport, or shipping must be labeled or color-coded and closed prior to being stored, transported, or shipped.

5. Equipment

Equipment that may become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary, unless the employer can demonstrate that decontamination of such equipment or portions of such equipment is not feasible, according to OSHA. A readily observable bio-hazard label shall be attached to the equipment stating which portions remain contaminated.

Ensure that you have bio-hazard labeling or color-coding, as necessary, in these five areas and in other areas of your facility that fall under the guidelines of OSHA’s Bloodborne Pathogens Standard 1910.1030.  In practice, most facilities typically use BOTH bio-hazard labeling AND color-coding in most cases.

For more information please join the LinkedIn group: The Healthcare Compliance Solutions Administrative Alert

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Safety in the Laboratory

Laboratory OSHA Safety Culture

                                                           

The safety culture varies greatly from laboratory to laboratory. Most lab employees these days know that eating food or drinking in the lab is against most, if not all, lab regulatory agency rules and guidelines. However, it is surprising that many do not seem to understand that gum chewing or using hard candy or throat lozenges is also not permitted in a laboratory setting.

                                                           

OSHA’s Bloodborne Pathogen Standard specifically states “Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.” Obviously, the goal of this regulation is to prevent employees from obtaining infection via ingestion. A secondary goal is to limit hand to mouth contact while working in the laboratory. So far there has been no mention of gum or cough drops in the standards.

                                                           

In the National Research Council’s Prudent Practices in the Laboratory (1995), it states “Eating, drinking, smoking, gum chewing, applying cosmetics, and taking medicine in laboratories where hazardous chemicals are used should be strictly prohibited.” In the Clinical and Laboratory Standards Institute’s document Clinical Laboratory Safety (GP-17 A3, 2012), it states “Food, drink and substances that provide potential hand-to-mouth contact (including chewing gum and lip balm) are prohibited in technical work areas.”

                                                           

Most inspectors of the laboratory will cite the lab for gum chewing or the like. An employee may respond that the gum was placed into their mouth outside the lab, but proving that would be difficult at best. It is an inappropriate and unsafe practice, and it should not be allowed.

                                                           

Again, limit hand-to-mouth or hand-to-face contact in the laboratory. What about telephone use? There are speaker options for phones that can help, but some labs are too noisy for that type of use. Disinfect phones often if that is the case.

As with any other safety regulation, if you explain it to staff, and if you make it easy to comply, your safety culture will improve. Educate your staff about these guidelines and standards and why they exist. Unfortunately, many workers fell victim to harmful infectious diseases before these regulations were developed. Don’t let your staff become another part of those unfortunate lab safety statistics.

5 Areas Requiring Bio-Hazard Labels

Five Areas that Require OSHA Bio-hazard Labeling

The Blood-borne Pathogens Standard outlines the regulations for bio-hazard labeling and color-coding. Three signals can alert you to the presence of a bio-hazard or bio-hazardous waste: the word “bio-hazard”, the bio-hazard symbol, or the fluorescent orange or orange-red color-coding.

These five areas are ones to watch for bio-hazard labeling in your facility:

●       Regulated medical waste containers and other containers

      According to OSHA, warning labels must be affixed to:

○     Containers of regulated waste,

○     Refrigerators and freezers containing blood or other potentially infectious material; and

○     Other containers used to store, transport or ship blood or other potentially infectious materials.

EXCEPTIONS include:

○     Containers of blood, blood components, or blood products that are labeled and have been released for transfusion,

○     Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal, or

○     Regulated waste that has been decontaminated.

●       Sharps Containers

Sharps containers must also be labeled or color-coded in accordance with the requirements of the Blood-borne Pathogens Standard.

●       Contaminated Laundry

The Blood-borne Pathogens Standard also requires contaminated laundry to be placed and transported in labeled or color-coded bags. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.

When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in labeled or color-coded bags or containers.

●       Specimens

Specimens of blood or other potentially infectious materials must be placed in a container which prevents leakage during collection, handling, processing, storage, transport, or shipping. The container for storage, transport, or shipping must be labeled or color-coded and closed prior to being stored, transported, or shipped.

●       Equipment

Equipment that may become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary, unless the employer can demonstrate that decontamination of such equipment or portions of such equipment is not feasible, according to OSHA. A readily observable bio-hazard label shall be attached to the equipment stating which portions remain contaminated.

Ensure that you have bio-hazard labeling or color-coding, as necessary, in these five areas and in other areas of your facility that fall under the guidelines of OSHA’s Blood-borne Pathogens Standard 1910.1030.  In practice, most facilities typically use BOTH bio-hazard labeling AND color-coding in most cases.

#osha