Deadline looming for training on chem labels
OSHA may ramp up citations after Dec. 1
The deadline is looming for hospitals and other employers to complete new training requirements for chemical safety — or face the possibility of citations from the U.S. Occupational Safety and Health Administration.
By December 1, hospitals and other employers must train all their employees how to read and understand new labels and safety data sheets that are part of the Globally Harmonized System (GHS) for the labeling of chemicals.
This switch to an international system has been an important move for OSHA, as the United States joins more than 65 other countries in adopting the uniform labels and safety sheets. Hazard Communications is the third most frequently cited standard in hospitals — and in general industry.
"The concept of having a worldwide format is way, way overdue," says Rick Cotter, president of RT Cotter & Associates in Plymouth, MA, which provides "environment of care" consulting and safety data sheet management. "We’re just going to go through the pain of making that transition over the next several years."
OSHA wants employees to be trained on the new pictograms, label wording and safety data sheets because manufacturers may gradually shift to the new system over the next couple of years. By June 1, 2015, manufacturers must fully comply with the new labeling and safety data sheets, and by June 1, 2016, employers must update their workplace labeling and hazard communications program and provide any new training, as necessary.
"Between now and , employees and employers should expect it’s going to be a bit of a mess," cautions Brad Harbaugh, editor of the EH&S blog for MSDSonline, which helps employers with chemical management and other safety compliance. "A lot of chemical manufacturers are making these changes a little at a time. The employer has to make sure they’re compliant with the old [Hazard Communications] standard or the new one in some combination during this transition period."
Train before new chemicals arrive
Meeting the December training requirements is rather simple. (See related story, p. 127.) But full compliance with the Hazard Communications standard requires hospitals to keep up with new chemicals that employees handle, including hazardous drugs.
(The Hazard Communication standard does not apply to drugs that are given in solid form to patients without being altered, such as pills or tablets. But it does apply to drugs that pose a risk of exposure when they’re handled, mixed, or administered.)
Your hazard communications plan should indicate who is in charge of managing chemicals, how to train employees, where to store safety data sheets, and how to re-label containers if they are taken out of the original container, says Harbaugh.
This involves conducting a complete chemical inventory. "It’s important that this includes any hazardous chemicals to which your employees are exposed, including paint and cleaning agents," he says.
OSHA requires employees to receive training before any new chemical is introduced, so that means being proactive, Harbaugh says.
"Start with doing a physical inventory of the chemicals in your facility," he adds. "When was the last time you walked around and opened every closet and every door and knew the chemicals that are actually being used in your facility?"
Be aware that changes in chemical concentrations can create a new hazard in an old product. For example, Stephen Burt, president of Healthcare Compliance Resources in Roanoke, VA, recalls one incident in which a hospital switched a glutaraldehyde product from 2.7% to 4.9% concentration. An environmental services worker had an adverse reaction to the higher concentration, including respiratory and eye problems.
Because of the greater hazard with a higher concentration, employees needed to be retrained, Burt says.
Quiz employees on hazard info
An OSHA inspector may ask for your hazard communication plan. But to gauge compliance, he or she may also ask employees about the hazards associated with a chemical they work with or where they would find the safety data sheet.
"If employees are working with chemicals, OSHA assumes they’ve been trained on the chemicals and the hazards associated with them," Harbaugh says.
The labels on hazardous products will be clear, with one of eight pictograms conveying the type of hazard. They will contain signal words: "warning" for a less severe hazard and "danger" for a more severe hazard. Labels also must contain a brief description of the hazard and precautions that should be taken.
That will make it easy for even employees with limited English proficiency to readily identify hazards. But OSHA also makes it clear that employees must be trained in a way they can understand — which means they may need training in their native language.
Safety data sheets will likely be available in multiple languages, particularly since the GHS has been adopted by so many countries, including China, Japan, Korea and the European Union.
To monitor compliance, Burt suggests randomly asking employees about a hazardous chemical they work with.
"When I do my walk-around and risk assessment for hospitals, I ask everyone from physicians to environmental services employees," he says. "They have to know how to access that information. Otherwise it’s a violation.
"What would you do if you splashed this in your eye? Do they know what they’re supposed to do? Where’s the eyewash station? Has anyone trained you on this?"
With a heightened focus on hazard communications, OSHA inspectors are likely to be asking much the same thing.
[Editor’s note: More information on the GHS and new Hazard Communications standard is available at www.osha.gov/dsg/hazcom/.]