OSHA adds emphasis to hazard communication

MSDSs may change, training needs reviewed

The Occupational Safety and Health Administration (OSHA) announced an initiative to emphasize hazard communication, an area that already is a routine part of inspections.

Every inspection — even those focused on a specific complaint — includes a review of hazard communication and record keeping, says Rich Fairfax, CIH, OSHA’s director of enforcement. Employers must have updated, accessible Material Safety Data Sheets (MSDSs) and must train employees on safe handling and use of personal protective equipment. "It all adds up to knowledge," he says. "If employees are trained and know what they’re working with, they’re going to take better precautions to protect themselves."

During inspections, "we ask as a part of our interview if the employees have been trained, [and] if they know where the data sheets are," Fairfax adds.

OSHA has developed a model training program for employers. They are required to provide training at the time of an employee’s initial assignment to work with hazardous chemicals and whenever a new physical or health hazard is introduced. "[N]o employee should be in the position of encountering unfamiliar or unknown hazards," the agency stated.

The guidance document, which was released in draft form this spring, outlines how employers should decide which employees to train and what that training should include. It includes information on developing lesson plans and compares different techniques of training, such as computer-assisted programs or small group activities. Employers should monitor the effectiveness of the training program and maintain adequate documentation, OSHA explained.

Employees need to be trained before they begin their assignment in a department, and they may need additional training if they move to an area that uses different hazardous chemicals or drugs, Fairfax says. Hospitals soon may need to update their MSDSs. OSHA announced that compliance officers will be reviewing MSDSs and checking them for accuracy and comprehensibility. (That enforcement action will be targeted toward manufacturers.)

"We’ve received a number of letters and calls over the last several months about inaccurate data sheets," Fairfax notes.

What about experimental drugs? "Often toxicological data are incomplete or unavailable for investigational drugs," according to the National Institute for Occupational Safety and Health hazardous (NIOSH) drug alert. "However, if the mechanism of action suggests that there may be a concern, it is prudent to handle them as hazardous drugs until adequate information becomes available to exclude them." NIOSH also points out that the Hazard Communication Standard applies "not only to health care professionals who provide direct patient care, but also to others who support patient care by participating in product acquisition, storage, transportation, housekeeping, and waste disposal."

(Editor’s note: The Draft Model Training Program for Hazard Communication is available at www.osha.gov/dsg/hazcom/MTP101703.html. For more information about the Hazard Communication Standard, go to www.osha.gov/SLTC/hazardcommunications/index.html.)