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Warning: Prepare to retrain hospital employees on chemical hazards
Labels, safety sheets to change with pending OSHA rule
Hospitals will need to retrain all their employees on chemical hazards when the U.S. Occupational Safety and Health Administration finalizes its changes to the Hazard Communication Standard.
The standard involves new pictograms and "signal" words on labels as well as revised safety data sheets (SDSs). For example, irritants and dermal or respiratory sensitizers would be marked with a black exclamation point surrounded by a red diamond.
With the proposed revisions, OSHA would bring hazard communication in line with international requirements a Globally Harmonized System of Classification and Labeling of Chemicals.
"With this rulemaking, OSHA is proposing to revise its requirements to increase the effectiveness of the Hazard Communication Standard and make it reflective of the 21st century workplace," Dorothy Doughtery, CIH, director of the Directorate of Standards and Guidance, said at a hearing on the proposed rule.
The bottom line, according to OSHA: New labeling will make it easier for workers to understand the hazards of various chemicals and the new SDS will be easier to read than the current MSDS (material safety data sheet). Employers would be required to train their employees on the new system within two years. OSHA's regulatory agenda says that the Hazard Communication Standard will be issued in final form in August.
"I'm going to be working very hard to come up with a completely new training program," says John Schaefer, CIH, HEM, CPEA, associate director of health safety and environment at Johns Hopkins University and Medical Institutions in Baltimore.
The changes also offer an opportunity to increase awareness and emphasize the proper engineering controls, such as ventilation, as well as use of personal protective equipment, Schaefer notes. "If we can get employees to understand a little more about what they're working with, it will be a beneficial," says Bruce Cunha, RN, MS, COHN-S, manager of employee health and safety at Marshfield (WI) Clinic.
In fact, in the preamble of its proposed rule, OSHA says that better communication about hazards could influence some employers to adopt less hazardous substitutes and can promote safer practices.
"Knowledgeable employees can take the steps required to work safely with chemicals, and are able to determine what actions are necessary if an emergency occurs. Information on chronic effects of exposure to hazardous chemicals helps employees recognize signs and symptoms of chronic disease and seek early treatment," OSHA said.
Not all hazards covered?
With cleaners, solvents, disinfectants, and even pesticides, hospital employees can be exposed to a wide variety of hazardous chemicals. Even so, some of the most hazardous substances in hospitals chemotherapeutic agents are not covered by the Hazard Communication Standard. The standard specifically excludes drugs and other substances from labeling requirements if they are regulated by the Food and Drug Administration.
The Association of Occupational Health Professionals in Healthcare (AOHP) asked OSHA to consider adding those to the standard, as well. Otherwise, AOHP endorsed the changes. "We support anything that would help healthcare workers become more knowledgeable about the chemical hazards in the workplace," says MaryAnn Gruden, manager of Employee Health Services at Allegheny General Hospital and the Western Pennsylvania Hospital in Pittsburgh and community liaison of AOHP.
She notes that the recent joint OSHA-NIOSH-Joint Commission letter to hospitals emphasizing safe handling of anti-neoplastic agents also will promote awareness about those hazards.
OSHA's proposed rule includes "unclassified hazards," for which there is not yet enough information. "Nano materials represent an example of the new potential hazard that may cause harm but has not yet been sufficiently studied to allow classification. For nanoscale materials, size and shape may be more important than chemical composition as a determinant of hazard," Paul Schulte, PhD, director of the Education and Information Division of the National Institute for Occupational Safety and Health said at a hearing.
Overall, OSHA's revised Hazard Communication Standard got favorable reviews and is likely to be one of the few rules that won't face a legal challenge, says Brad Hammock, an attorney with Jackson Lewis in Reston, VA, who specializes in occupational health law.
"As you get integrated into the [Globally Harmonized System], it will be more understandable for employees, employers and manufacturers," he says.
The standard changes offer an opportunity for hospitals to reassess their chemical hazards, revise their hazard communication program, and improve awareness of the hazards among employees, says Hammock.
"Hazard communication is a fundamental linchpin of your safety and health program. From an OSHA compliance standpoint, it's like a building block for everything," he says. "It's a major mechanism to inform employees of where your hazards are and what is required to protect against those hazards."
Too often, health care employers don't have a full, written hazard communication program, he says. "[This is] an opportunity to ensure you've got your hazard communications plan in order and your safety data sheets up to date, and to make sure you have your employees in the correct protection," he says.