Thursday, February 15, 2018

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.
 HCSI OSHA Training

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Safety Data Sheets (SDS) [previously called Material Safety Data Sheets (MSDS) which are now obsolete and superseded by the GHS Global Harmonized Standard implemented in 2013 replacing MSDSs with SDSs] are forms generally provided by chemical manufacturers that convey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. 


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Thursday, February 8, 2018

Protecting Doctors from Themselves

While practicing medicine, doctors must
protect their own integrity and reputation

It is a story that we were all shocked to hear about. USA Gymnastics Medical Professional and his inappropriate conduct with his patients and others. It is situations like this that make patients either grateful for or suspicious of the doctor they have.

Reality Time

When something so dramatic and public as the USA Gymnastics situation happens, it has numerous effects:
  1. Patients who are victims of such horrific acts may develop the courage to speak out and tell their story.
  2. Some people will begin looking for this type of situation in their life and find it, even if it does not exist.
  3. There are people who are looking for the social media spotlight and begin making accusations in order to gain attention.
What Can a Doctor Do?

It is vital that a doctor take appropriate steps to protect him or herself from a possibly career ending situation:
  • Continually communicate with the patient throughout their visit. They should know what the doctor is doing and why.
  • Have written policies and procedures in place that focus on harassment and inappropriate conduct within the office. These policies should also include appropriate interactions with patients. This training should include ALL staff members including doctors and be done annually as well being thoroughly documented.
  • Create a culture within the healthcare office of acting professionally and being current with all compliance laws.
  • Communicate with patients that if at anytime they do not feel comfortable with the doctor or other staff members, that they are welcome to have an additional person of the same gender in the room during their visit.
  • If the doctor does not feel comfortable being alone with the patient, then he or she should request and additional person (e.g. nurse or physician assistant) be present during the visit.
Possible Consequences

If a doctor is accused of some inappropriate behavior with a patient, then that doctor's reputation could be irrevocably damaged. It does not matter if the accusation has any truth to it, people will remember and the damage is done. It is best for the doctor to protect him or herself and avoid even the slightest hint of inappropriate behavior.

This type of situation cannot be taken lightly. Many doctors push away training, especially HR training, as inconvenient and a time waster. They do not understand that HR and other training's are in place for their protection. Documented HR and conduct training would play a key role in protecting a doctor and the reputation of the practice.

It is completely understandable that doctors want to focus only on practicing medicine, but they do not need to put themselves and their career at risk when doing so.

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