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Osha Regulatory Manual For Health Care

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OSHA

regulatory
manual
for healthcare
Table of contents

Chapter 1: Hazard communication policy . . . . . . . . . . . . . . . . . . . . . . . . .3

Chapter 2: Bloodborne pathogens policy . . . . . . . . . . . . . . . . . . . . . . . .67

Chapter 3: Sharps safety policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .147

Chapter 4: Recordkeeping forms and tests . . . . . . . . . . . . . . . . . . . . . .169

Chapter 5: Safety and health program: Injury and illness


prevention program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .201

Chapter 6: Emergency preparedness and disaster planning . . . . . . . .213

Chapter 7: Electrical and mechanical policy . . . . . . . . . . . . . . . . . . . . .243

Chapter 8: Tuberculosis exposure control plan . . . . . . . . . . . . . . . . . . .259

Chapter 9: Ergonomics control plan . . . . . . . . . . . . . . . . . . . . . . . . . . .269

Chapter 10: Workplace violence prevention program . . . . . . . . . . . . . .283

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Table of contents

Chapter 1: Hazard communication policy


Purpose of the sample hazard communication policy . . . . . . . . . . . . . . . . . . . . . . .3
Preparing the hazardous chemical substance list . . . . . . . . . . . . . . . . . . . . . . . . . . .4
Training requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
Contractors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8
Responsibility and steps for hazard determination . . . . . . . . . . . . . . . . . . . . . . . . .8
MSDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
Hazardous drug standard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
Labeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19
PPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21
Safety precautions for radiation and laser areas . . . . . . . . . . . . . . . . . . . . . . . . . .27
Controlling waste anesthetic gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30
Spill cleanup procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Medical and first aid instruction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36

Figure 1.1: Common hazardous drugs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6


Figure 1.2: Sample material safety data sheet . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
Figure 1.3: Target organ effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39
Figure 1.4: Glossary of terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40
Figure 1.5: Occupational hazards by location in healthcare facilities . . . . . . . . .41
Figure 1.6: Hazard communication compliance check-off list . . . . . . . . . . . . . . . .45
Figure 1.7: OSHA hazard communication federal standard—1910.1200 . . . . . . .46
Figure 1.8: Emergency eyewash equipment standards . . . . . . . . . . . . . . . . . . . . .60
CHAPTER 1

Hazard communication policy

Purpose of the sample hazard communication policy

The purpose of this hazard communication policy is to inform employees that the office of
_______________________________________________________ has named
_______________________________________________________ as the safety officer in charge
of the hazard communication program, in compliance with OSHA hazard communication
standard, Title 29, Federal Regulations Code 1910.1200. The safety officer has the full support
and authority of the employer to ensure compliance with this OSHA standard.

Employers and their employees must meet the hazard communication standard, which
instructs them in achieving compliance. This includes making the facility a safe and healthy
workplace by doing the following:
• Determining hazards and preparing a list of hazardous chemical substances in the workplace
• Compiling a library of material safety data sheets (MSDS)
• Properly labeling all containers
• Establishing workplace safety practices
• Fulfilling the requirements for employee training in these workplace safety practices

The hazard communication policy teaches


• the hazardous nature of the chemical substances and physical hazards in this workplace
• proper and safe handling procedures
• the steps employees must take to protect themselves and others from harm in this workplace

This office conducts training sessions to teach compliance responsibilities. The information
and training sessions teach what containers to label and how to do so, how to order and file

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C HAPTER 1—H AZARD COMMUNICATION POLICY

MSDSs, and other associated tasks. In addition, copies of the official standard and written
training materials are available from the safety officer. The safety officer will review this policy
biennially for any revisions or updates that may be necessary.

The OSHA standard requires employers to assess the chemical hazards to which an employee
may be exposed in the workplace under normal conditions or possible emergencies. An emer-
gency includes equipment failure, container rupture, release of a hazardous chemical into the
workplace, or anything that constitutes a danger to employee health.

OSHA requires all employees to familiarize themselves with the hazard communication policy.
See Fig.1.7 for a copy of the OSHA standard.

The hazard communication policy is available for employee review and is located at
____________________________________________________________________

Preparing the hazardous chemical substance list

A hazardous chemical substance list must account for every hazardous product used in each
location of the healthcare facility. It must include the following information:
• Location
• Chemical name
• Brand name
• Address of manufacturer
• Intended use of the product
• Hazards of the product
• Target organs

Compliance with OSHA requires preparation of a hazardous chemical substance list for each
location in the practice. You may find the list of common hazardous drugs in Fig. 1.1 helpful
when preparing your hazardous chemical substance list.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

To fill out the list in Fig. 4.2 in Chapter 4, inspect every bottle, carton, and cylinder in your
healthcare facility. Record every container with hazardous contents on the list. Words and
phrases such as, “flammable,” “requires ventilated area,” and “do not heat beyond 120° F” are
indications to list these substances.

In the column that calls for the product’s use in your facility, describe the use in one or two
words, such as “disinfectant” or “x-ray developer.”

The “target organ” column includes short statements that indicate how the substance affects
human organs and bodily systems. Use phrases such as “burns eyes” or “damages lungs.”

List the personal protective equipment (PPE) that employees must wear while using this
chemical. This information can be found on the MSDS.

Use the last column as a check-off list for the safety officer to indicate whether an MSDS is on
file for the hazardous material listed.

A thorough, up-to-date, error-free hazardous chemical substance list is essential for the prac-
tice. The safety officer is ultimately responsible for the accuracy of this list.

Facilities with 11 or more employees may list the chemicals by room. Facilities with fewer
than 11 employees may create a single list containing all the chemicals. Either method is
acceptable.

File the master hazardous chemical substance list in a safe location, such as with the MSDS
file or with the OSHA records for the facility.

The master hazardous chemical substance list is located at


___________________________________________________________________

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.1 Common hazardous drugs


Aldesleukin Diethylstilbestrol Interferon alfa-n1 Progesterone
Alemtuzumab Dinoprostone Interferon alfa-n3 Progestins
Alitretinoin Docetaxel Irinotecan HCl Raloxifene
Altretamine Doxorubicin Leflunomide Raltitrexed
Amsacrine Dutasteride Letrozole Ribavirin
Anastrozole Epirubicin Leuprolide acetate Rituximab
Arsenic Trioxide Ergonovine/ Methylergonovine Lomustine Streptozocin
Asparaginase Estradiol Mechlorethamine Tacrolimus
Azacitidine Estramustine phosphate sodium Megestrol Tamoxifen
Azathioprine Estrogen-progestin combinations Melphalan Temozolomide
Bacillus Calmette Guerin Estrogens, esterified Menotropins Teniposide
Estrogens, conjugated Estrone Mercaptopurine Testolactone
Bexarotene Estropipate Methotrexate Testosterone
Bicalutamide Etoposide Methyltestosterone Thalidomide
Bleomycin Exemestane Mifepristone Thioguanine
Busulfan Finasteride Mitomycin Thiotepa
Capecitabine Floxuridine Mitotane Topotecan
Carboplatin Fludarabine Mitoxantrone HCl Toremifene citrate
Carmustine Fluorouracil Mycophenolate mofetil Tositumomab
Cetrorelix acetate Fluoxymesterone Nafarelin Trastuzumab
Chlorambucil Flutamide Nilutamide Tretinoin
Chloramphenicol Fulvestrant Oxaliplatin Trifluridine
Choriogonadotropin alfa Ganciclovir Oxytocin Trimetrexate glucuronate
Cidofovir Ganirelix acetate Paclitaxel Triptorelin
Cisplatin Gemcitabine Pegaspargase Uracil mustard
Cladribine Gemtuzumab ozogamicin Pentamidine isethionate Valganciclovir
Colchicine Gonadotropin, chorionic Pentostatin Valrubicin
Cyclophosphamide Goserelin Perphosphamide Vidarabine
Cytarabine Hydroxyurea Pipobroman Vinblastine sulfate
Cyclosporin Ibritumomab tiuxetan Piritrexim isethionate Vincristine sulfate
Dacarbazine Idarubicin Plicamycin Vindesine
Dactinomycin Ifosfamide Podoflilox Vinorelbine tartrate
Daunorubicin HCl Imatinib mesylate Podophyllum resin Zidovudine
Denileukin Interferon alfa-2a Prednimustine
Dienestrol Interferon alfa-2b Procarbazine

*Source: National Institute of Occupational Safety and Health, Preventing Occupational Exposures to Antineoplastic and Other
Hazardous Drugs in Healthcare Settings, April 2004, www.cdc.gov/niosh/docs/2004-HazDrugAlert/.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Training requirements

OSHA requires training for hazard communication at specific times and on certain occasions.
Training must be appropriate to the employee’s education, literacy level, and language. The
employer must provide information to train each employee who may be exposed to hazardous
chemicals prior to work assignment and whenever the hazard changes. The trainer does not
have to possess a special degree, but OSHA requires the trainer to understand clearly the
material covered.

Below is a schedule of a typical year’s training cycle:


• Commencement of employment. All employees receive training in the basic hazard
communication standard at the beginning of employment by means of a hazard commu-
nication training videotape, a written program, or an explanation by the trainer. New
employees learn about MSDSs and are able to demonstrate an understanding of the
MSDSs for chemicals they will handle before they begin work.

• New products in the workplace. Employees receive additional training with the intro-
duction of new hazardous products into the work area.

• A new procedure or a new technique. Employees receive additional training when the
chemical manufacturer or employee changes safe handling or emergency procedures.
Employees changing job functions within the facility receive training prior to commence-
ment of duties.

• Annual training. OSHA recommends but does not require annual training to review new
chemicals that have entered the workplace since the last training, any new handling pro-
cedures, and any changes in MSDSs or new MSDSs on-site.

Note: Some insurance agencies require a list of hazardous chemicals operations in specific
work areas. An example would be posting in the appropriate room a step-by-step guideline for
the use of glutaraldehyde in the cleaning of an endoscope. This is not an OSHA requirement.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Contractors

Occasionally this facility may require the services of non-employees or contractors. A contrac-
tor receives a fee, not a W-2 form wage. To protect the contractor’s health and safety and to
reduce the liability of this facility, the safety officer will provide the following to him or her:
• Work site information. Review with the contractor any potential health hazards in the
work area.

• An MSDS review. Provide MSDS information to the contractor if he or she will be in


contact with chemicals used by the facility.

• Equipment. Provide the appropriate PPE.

Responsibility and steps for hazard determination

The hazard communication standard says that the employer may use information from the
chemical manufacturer or importer for hazard determination. The following are the steps for
hazard determination:
• Identify hazards. The manufacturer identifies any hazards associated with its products.
Hazards appear on the label of the product as warnings and precautions. Use the
hazardous chemical substance list in Fig. 4.2 to help you determine the hazards.

• Order MSDSs. Once the safety officer determines that a product is hazardous, order an
MSDS from the manufacturer. Do so by phone, fax, form letter, or e-mail. If there is any
question about whether a chemical is hazardous, presume that it is, and let the MSDS
ultimately answer the question.

• Arrange MSDSs. The facility has alphabetized files—typically in a binder—that contain


an MSDS for every hazardous product.

• Train personnel. The safety officer will ensure that the MSDS is complete and will train
affected employees about the substances and related safety topics.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

MSDS

An MSDS for each hazardous chemical is necessary because it contains important safety and
health information about the chemical. See the sample MSDS in Fig. 1.2.

The manufacturer is responsible for creating an MSDS before marketing the product. Manu-
facturers or distributors are responsible for providing an MSDS with the initial shipment of the
hazardous chemical or on request by the product user. MSDSs are not interchangeable; each
product must have its own. If there is a conflict between information on the label and in the
MSDS, the MSDS prevails.

If in doubt about the necessity of an MSDS, order one. The order request is important for
documentation. Keep a copy of the letter, fax, or e-mail, or keep a record of the phone request
on file until receiving the MSDS.

All employees must be familiar with the MSDS for each hazardous product they use. The
employer must not introduce hazardous chemicals into the workplace until MSDSs are on file
and employees have undergone training on them.

Household products (exempt items)


OSHA does not consider household products—i.e., those readily available to consumers—
hazardous unless used in a manner or quantity different from the instructions on the label.
Nevertheless, this facility obtains an MSDS as an extra measure of safety if the product could
seriously affect the health and safety of staff. These products include but are not limited to
Clorox, Lysol, Ajax, and ethyl alcohol.

Availability of the MSDS binder


The MSDSs appear in alphabetical order by brand name in a binder reserved exclusively for
them. Alphabetical organization of the binder promotes quick and efficient retrieval. MSDSs
are in English, but secondary MSDSs in other languages are also available. Keep the binder in
a central location in the facility.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

In this facility, the master MSDS binder is located at:


________________________________________________________________

Figure 1.2 Sample material safety data sheet

Chemtrec Emergency phone: 800/000-0000

Material safety data sheet

Wavicide-01

Section 1—Product identity

Product name: Wavicide–01 (2.5% Glutaraldehyde solution) Chemical sterilant/disinfectant

EPA registration number: 15136-1

Manufactured by: Medical Chemical Corporation


25 Manaard Ct., Wayne, NJ 07470 and
1909 Centinela Ave., Santa Monica, CA 90404

Section 2—Ingredients (typical values—not specifications)

Case number % W/V OSHA PEL ACGIH TLV


Glutaraldehyde 111-30-8 2.5 0.2 ppm* 0.2 ppm

*Note: The OSHA PEL for glutaraldehyde was invalidated in 1992 by court order. However, the PEL
may remain valid in some states.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.2 Sample material safety data sheet (cont.)

Section 3—Physical data

Molecular weight: 100.11 Odor threshold: 0.04 ppm, detectable


Boiling point: 212°F, 100°C Solubility in water: Completely soluble
VAP pressure: 16.9 mmHg @ 20° Specific gravity: 1.005–1.013 (25/25°C)
VAP density: 1.1 (air = 1) pH: 6.3
Appearance: Clear, slightly yellow Odor: Aldehyde odor, lemon scent added
Freezing point: 0°C/32°F Evaporation rate: 0.81

Section 4—Fire and explosion hazard data

Flash point: None Flammable limits


Method used: TCC ASTM 056 LFL/UFL: Not applicable
Extinguishing media: Carbon dioxide, foam, dry chemical
Special firefighting equipment and hazards: Self-contained breathing apparatus and protective
clothing should be worn.

Section 5—Reactivity data

Stability (conditions to avoid): Alkaline (pH>10) and acidic (pH<3). Avoid high temperatures
(>40°C/104°F) and evaporation of H20.

Incompatibility (specific materials to avoid): Avoid contact with acids and alkaline materials.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.2 Sample material safety data sheet (cont.)

Hazardous decomposition products: Thermal decomposition may produce carbon dioxide and
carbon monoxide.

Hazardous polymerization: Will not occur.

Section 6—Specific hazards

Avoid alkaline (pH>10) and acidic (pH<3) conditions.

Section 7—Ingredients (typical values—not specifications)

Eye: May cause severe corneal injury that could cause permanent impairment. Vapors may cause
stinging sensation in the eye with excess tearing, blinking, and redness of the conjunctiva.

Skin contact: Direct contact may cause irritation or aggravation of existing dermatitis. May also
cause the skin to turn a harmless yellow or brown color.

Ingestion: May cause irritation and possibly chemical burns in the mouth, throat, stomach, and
esophagus. May produce discomfort in the mouth, throat, chest, and abdomen, and may lead to
nausea, vomiting, diarrhea, dizziness, faintness, drowsiness, thirst, and weakness.

Inhalation: Vapor is irritating to the respiratory tract. May cause stinging sensations in the nose
and throat, chest discomfort and tightening, difficulty with breathing, and headaches. May also
aggravate pre-existing asthma and pulmonary disease.

Carcinogenicity: Not listed as carcinogen by NTP, OSHA, or IARC.

General: Medical conditions are aggravated by overexposure.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.2 Sample material safety data sheet (cont.)

Section 8—First aid

Eyes: Irrigate with flowing water immediately and continuously for 15 minutes. Consult medical
personnel immediately and follow up with an ophthalmologist.

Skin: Immediately remove contaminated clothing and flush skin with soap and water for a
minimum of 15 minutes. If irritation persists, seek medical attention. Discard or wash
contaminated clothing.

Ingestion: Do not induce vomiting. Drink large quantities of water and call a physician
immediately.

Inhalation: Move to fresh air. Give artificial respiration if not breathing. If breathing is difficult,
qualified personnel may give oxygen. If irritation persists, seek medical help.

Note to physician: Probable mucosal damage from oral exposure may contraindicate the use of
gastric lavage.

Section 9—Special handling information

Respiratory protection: A full-face respirator, or half-face respirator with gas-proof goggles, both
worn with organic vapor cartridges, is recommended for small spills. A respirator is essential for
large spills, or if you experience discomfort, watery eyes, or nasal or respiratory irritation due to
inadequate ventilation.

Protective clothing: Wear suitable protective equipment, including nitrile gloves, a chemical-resis-
tant gown or apron, and protective eyewear (safety glasses or eye shield).

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.2 Sample material safety data sheet (cont.)

Section 9—Special handling information (cont.)

Eye protection: Safety glasses, goggles, or a face shield is recommended. An eye wash and full-
face respirator with organic vapor cartridges or half-face respirator with gas-proof goggles and
organic vapor cartridges should be available for emergency situations.

Section 10—Spill, leak, and disposal procedures

Action to take for spills/leaks: Isolate damaged goods. Spills should be diluted with water, then
soaked up with suitable absorbent material.

Disposal method: Dispose of WAVICIDE-01 after 30 days of reuse or when the MEC indicator
shows the solution is below its minimum effective concentration (1.7% w/v), whichever is sooner.
This may be accomplished by pouring solution down the drain in accordance with state and local
regulations. Flush with a large quantity of water and dispose of in trash.

For small spills of 1 gal or less, gather up a bucket, household ammonia, and a sponge or mop.
Don protective equipment and mix approximately 1 cup of ammonia with 1 cup of water in the
bucket. Mop or sponge the ammonia mixture into the spill until thoroughly combined (about 2 min-
utes). Wipe or mop up resulting mixture and discard down the drain with a copious amount of
water. Rinse bucket, mop, or sponge with water, and give spill area a final wipe or mop with fresh
water. Rerinse all equipment, and allow spill area to dry.

For large spills of more than 1 gal, remove people from immediate spill area, and isolate until
cleaned up. Don protective equipment, including a respirator with organic vapor cartridges.
Contain spill with absorbent material (e.g., towels). Add the glutaraldehyde neutralizer kit con-
tents or add approximately 228 grams of sodium bisulfite powder per gallon of WAVICIDE-01

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C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.2 Sample material safety data sheet (cont.)

Section 10—Spill, leak, and disposal procedures (cont.)

spilled (aqueous sodium hydroxide and ammonium will also neutralize glutaraldehyde). With a
sponge, mix neutralizing chemical into spill, and allow 5 minutes for deactivation to occur. Discard
resulting mixture according to your facility’s waste disposal guidelines. Mop spill area with fresh
water. Rinse out all equipment (bucket, mop, and towels) with large amounts of water. If paper
towels were used, dispose of in a tightly closed trash bag. Let spill area dry, and if possible,
increase ventilation. Once glutaraldehyde odor is below allowable levels (threshold limit values or
TLV), release the area from isolation.

Section 11—Special precautions and additional information

Precautions to be taken in handling and storage: Store in original container at controlled room
temperature (15° C/50°F to 30° C/85° F).

Ventilation: Use WAVICIDE-01 in closed containers with tight-fitting lids. The working area should
be large enough with adequate ventilation to keep the level of atmospheric glutaraldehyde below
the TLV. If the solution vapors are irritating to eyes and nose, the TLV is probably being exceeded,
and additional ventilation may be necessary. If adequate exhaust ventilation is not available, then
a fume hood or self-contained fume absorber may be necessary. Good ventilation should pull
vapors away from worker and toward the floor.

Note: The information herein is given in good faith, but no warranty, expressed or implied,
is made.

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C HAPTER 1—H AZARD COMMUNICATION POLICY

For facilities with more than 25 employees, each department has copies of the MSDSs from
the master binder for hazardous substances used in that work area.

With the discontinuation of a hazardous chemical or drug, the safety officer removes the item
from the chemical substance list and retires the MSDS to an old or unused MSDS file. This
facility retains discontinued MSDSs for five years.

Electronic MSDSs
Electronic or online MSDS systems are compliant when they meet the following criteria:
• The MSDS is readily accessible, and there are no barriers to employee access of the files.
This includes ensuring that reliable devices are quickly available in the workplace at all
times.
• Employees receive training in the use of retrieval devices or software.
• There is an adequate backup system for rapid access to hazard information in the event
of power outages, equipment failure, online access delays, etc.
• Employees can obtain hard copies of the MSDS if needed or desired.
• Procedures are in place for providing hard copy MSDSs to emergency response personnel.

Hazardous drug standard

OSHA Instruction CPL 2-2.20B of April 14, 1995, calls for a written hazardous drug safety and
health plan to protect employees from health hazards when hazardous drugs are present in
the workplace. This section of the hazard communication plan fulfills the OSHA requirement.

The safety officer is responsible for carrying out the plan and makes it accessible to all
employees, temporary employees, contractors, and trainees. The plan follows recommenda-
tions from the American Society of Hospital Pharmacists (ASHP).

Exempt items: MSDSs are not required for tablets, pills, and capsules that are ready for direct
administration to the patient (including manufacturer samples), drugs packaged by the manu-
facturer for sale to consumers (i.e., over-the-counter drugs), and drugs intended for personal
consumption by employees in the workplace (e.g., aspirin or first-aid items).

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C HAPTER 1—H AZARD COMMUNICATION POLICY

If the substance is a powerful chemical, obtain an MSDS to be safe.

Hazardous drugs defined


A hazardous drug may cause toxic effects to a worker in the course of his or her job duties.
Workers must understand the characteristics of hazardous drugs. According to the ASHP, there
are four characteristics used in identifying a hazardous drug:
1. Genotoxicity (causes damage to DNA and thereby may cause mutation or cancer)
2. Carcinogenicity (causes cancer)
3. Teratogenicity (capable of causing fertility impairment or fetus malformation)
4. Serious organ or other toxic manifestation at low doses in experimental animals or
treated patients

There is no standard reference for acquiring this information, nor, according to OSHA, is
there a complete consensus on all the agents listed above. The Physicians Desk Reference is an
acceptable source for determining hazardous characteristics, but it is not a substitute for a
hazardous drug MSDS. Seek the professional judgment of a physician or pharmacist to deter-
mine whether a drug is unsafe to employees.

Preparation of hazardous drugs


When healthcare workers prepare hazardous drugs, ASHP recommends that they do so in a
restricted location identified by signs restricting access to authorized personnel. Wherever
possible, employees use Class II or III biological safety cabinets to minimize exposure
during preparation.

Eating, drinking, smoking, chewing gum, applying cosmetics, and storing food in the prepara-
tion area is prohibited. Display spill cleanup and other emergency procedures in the work area.

Employees should wear appropriate PPE during preparation of hazardous drugs, including
gloves (either latex or hypoallergenic alternatives), unless the manufacturer specifies another
glove material. Thick, long latex gloves that cover the gown cuff are recommended. Use a dou-
ble layer of the gloves if doing so does not interfere with the technique. Change gloves hourly
or immediately after they tear, puncture, or become contaminated due to a spill. Wash your

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C HAPTER 1—H AZARD COMMUNICATION POLICY

hands before and after wearing gloves. Wear waterproof, disposable gowns with long sleeves
and elastic or knit cuffs for tucking under gloves. With double-gloving, wear the cuff over the
inner glove and tucked under the outer glove.

In the absence of a biological safety cabinet, use an appropriate National Institute of


Occupational Safety and Health (NIOSH)-approved respirator, as noted in the MSDS. Surgical
masks do not prevent aerosol inhalation.

Whenever splashes or sprays of hazardous drugs occur, use chemical barrier face and eye pro-
tection. Eyeglasses with temporary side shields are not adequate protection and should not
be used. Wear a plastic face shield or splash goggles. If the safety glasses interfere with the
use of a respirator, use a respirator with a full face piece.

See the “personal protective equipment” section of this chapter for more information.

Hazardous drug MSDS


The safety officer must have MSDSs for hazardous drugs on file. In this case, a separate binder
for hazardous drugs is compliant. Place copies of MSDSs in areas where hazardous drugs are
stored or prepared.

Employee training
OSHA recommends that an annual review for employees handling hazardous drugs include
the following:
• Physical and health hazards of hazardous drugs
• Measures for protection from these hazards
• Identification of the hazardous drugs in the healthcare setting
• Appropriate work practices for special situation drugs, such as avoidance of vapors, etc.
• Emergency procedures for spills and avoiding exposure
• Personal protective equipment to wear when using special situation drugs
• The labeling system of hazardous drugs and the MSDS

Use the training record in Fig.4.12 in Chapter 4 for employees who attend the hazardous
drug training session. Include the dates of the training session, the contents of the training

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session, the names and qualifications of the persons who conduct the training, and the
names and job titles of all persons who attend the training sessions. Maintain training
records for three years from the date on which the training occurred.

Hazardous drug exposures


If an exposure to a hazardous drug occurs, complete an employee exposure incident form (see
Fig. 4.18) and an accident investigation report (see Fig. 4.24).

Common hazardous drugs


Fig. 1.1 contains a list of potentially hazardous drugs commonly found in medical facilities.
OSHA compiled this list in consultation with expert sources. This list does not include every
hazardous drug. Use it as a starting point for identifying hazardous drugs in your healthcare
facility.

When in doubt about a drug’s hazardous properties, obtain an MSDS for it.

Labeling

OSHA requires labeling for all containers of hazardous chemicals that are not in their original
labeled containers. This facility labels all materials, hazardous or not, that are not in
original containers.

Designating one person to supervise labeling in-house containers is a sound practice. That per-
son will label any new items that come into facility, update the Hazardous Chemical Substance List
with the new item, and ensure that an MSDS is on file before releasing the product for use.

Manufactured products in their original containers with labels already have hazard warnings
(e.g., flammable, explosive, eye irritant, etc.). These containers do not need in-house labeling.

For a chemical not in its original container, affix a label to the new container and clearly
note on it
• the brand name of the material
• the chemical identity of the material in the product

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• the name and phone number of the manufacturer


• the target organ(s) affected by the chemicals in the material

Sample label
The sample label below shows how to properly fill one out. Clearly print information on labels
and cover with clear, waterproof
Label information
tape for permanency. A complete
Brand name: Cidex
label includes all of the information
Chemical name: Glutaraldehyde
on this sample label. A good, clear
Manufacturer: Johnson & Johnson
photocopy of the original label is
Cleveland, OH
permissible as the label for a trans-
Phone: 800/000-0000
fer container, if the original label is
Hazard warning (Include target organ):
not defaced and is legible.
Vapors dangerous to the lungs.
Liquids can cause blindness.
Lungs, eyes.

Sample in-house label


No labels are required for a temporary container if the chemical’s use is immediate and the
user does not leave the container unattended.

Brand name: Cidex Chemical name: Glutaraldehyde


Manufacturer: Johnson & Johnson, Cleveland, OH
Phone: 800/000-0000
Hazard warning: Vapors dangerous to the lungs.
Liquids can cause blindness. Lungs, eyes.

OSHA requires that a label be “at, on, or near” the container. Therefore, if a boat of glutaralde-
hyde is on the counter, a sign on the wall above it (“near”) referring to the solution is compli-
ant. It would read, “The rectangular boat below contains a glutaraldehyde solution as follows:”

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Eyewash stations
The employer must provide immediately accessible emergency eyewash station for employees
who use chemical substances that are hazardous to the eyes. If the MSDS for the chemical
requires eye irrigation of 15 minutes for exposure, the facility must have an eye wash unit
located within 10 seconds from the area that meets the MSDS requirement. (See the
Emergency eyewash equipment standard in Fig. 1.8.)

PPE

Under OSHA Standards 29 CFR 1910.132–136 and 138, the employer must provide PPE wher-
ever employees might have exposure to substances that can cause harm. This facility conducts
required hazard assessments and training to protect employees from exposure to harmful sub-
stances. The MSDS of each hazardous substance lists the PPE required for every kind of emer-
gency spill or general use of each chemical. Each employee must know the requirements for
the products used.

General requirements for hazard protection (1910.132)


According to OSHA standard 1910.132’s general requirements, this facility provides employees
with PPE wherever exposure to hazardous physical, chemical, or biological agents can cause
injury or other impairments through inhalation, absorption, or other physical contact. This
policy amplifies PPE instructions that may already be covered in other policies in this facility.
PPE includes, but is not limited to, protective equipment such as gloves and goggles; protec-
tive clothing such as gowns, respiratory devices, and protective shields; and barriers for eye,
face, head, foot, hand, and torso protection.

Hazard assessment certification


Employers must assess the workplace to determine which hazards are likely to be present and
which may require the use of PPE.

OSHA requires that employers create a workplace hazard assessment that includes a written
certification form identifying the areas of the workplace and what hazards have been noted in
each area. Fig. 4.2, the OSHA hazardous chemical substance list, satisfies that requirement in
this facility. The certification

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• identifies the document as certification of hazard assessment


• states the PPE required for protection from hazards
• documents who performed the evaluation and the date of the hazard assessment

The employer must


• communicate to each affected employee which hazards require what equipment
• require employees to use PPE protection from the hazards identified in the assessment
• properly fit the equipment to each affected employee
• ensure that defective or damaged PPE is not used
• provide all safety equipment called for on the MSDS in case of spills and accidents

Employee training
Employers must train all employees how to use PPE required in their areas, including
• when PPE is needed
• how to put on, take off, adjust, and wear the equipment
• the limitations of the equipment
• the proper care, maintenance, useful life, and disposal of the equipment

Each affected employee must demonstrate how to use the PPE before being allowed to per-
form work using it. Retraining is required if changes in the workplace or in the types of PPE
make previous training obsolete. When an employer believes that an affected employee
does not have the understanding and skill required to use his or her PPE, the employer
must retrain the employee.

Eye and face protection (1910.133)


OSHA standard 1910.133, eye and face protection, requires goggles, shielded glasses, and
masks or face shields where there may be a possibility of injury from flying particles, molten
metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially
injurious light radiation.

Employees must wear masks in combination with eye protection devices whenever splashes,
spray, splatter, or droplets of blood or other potential infectious materials may be generated

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and they anticipate eye, nose, or mouth contamination. For more information, see Chapter 2.

Employees must use eye protection that provides side protection when there is a hazard from
flying objects. Detachable side protectors, such as clip-on or slide-on side shields, are accept-
able, except when working with hazardous drugs.

Employees must wear appropriate eye protection when using machinery that produces dust
and chips, such as bone saws, and when handling toxic and corrosive substances.

Healthcare facility tasks may require eye or face protection during laser surgery, laboratory
work, medical equipment sterilization, and patient procedures that may produce blood
splashes and while using disinfectants, sterilants, and cleaning chemicals in the workplace.
Supervisors and visitors to the work area must wear required protective gear where tasks
requiring eye protection are in progress.

Eye protection must meet certain minimum requirements under 29 CFR 1910.133, Eye and
face protection. It must provide adequate protection against the particular hazards to which
the employee is exposed.

The equipment should be comfortable, easy to clean, and capable of being disinfected. The fit
should be snug enough to protect the employee properly and still not restrict his or her move-
ment. The equipment should be durable, be kept clean, and be kept in good repair.

Employees who wear glasses for vision correction may comply with the OSHA requirements by
wearing any of the following:
• Safety glasses that have the optical correction incorporated in the protective lenses
• Goggles that fit over corrective glasses without disturbing them
• Goggles that have a pair of corrective lenses mounted behind the protective lenses

Employees must use equipment with filter lenses that have a shade number appropriate for
the work being performed for protection from injurious light radiation.

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Clearly mark eye and face protection devices to facilitate identification of the manufacturer. This
protection should be designed, tested, and constructed in accordance with the American
National Standards Institute requirements for occupational eye and face protection. Employees
must have information about any limitations and precautions indicated by the manufacturer.

Respiratory protection (1910.134)


OSHA standard 1910.134, respiratory protection, covers employees in this facility when they
handle hazardous products or respond to spills. The same standard applies to respirator use
for tuberculosis exposure and is covered in Chapter 8 of this manual. The standard requires
employers to have a formal respiratory protection program if employees use respirators.

The program must encompass the following requirements:


• Respirator selection must protect against the specific hazards of exposure, such as glu-
taraldehydes and formalin.

• Employees must be physically able to perform the work and use the respirator equip-
ment. A physician or other licensed healthcare professional will assess the employee’s
health and physical condition before respirator use.

• Additional medical evaluations are necessary when the employee reports medical signs
or symptoms related to respirator use. A physician, licensed healthcare professional,
supervisor, or respirator program administrator informs the employer that an employee
needs reevaluation. Observations such as fit-testing and program assessment indicate a
need for employee reevaluation. Changing conditions in the workplace increase the physi-
ological burden placed on an employee.

• The organization will evaluate the respirator user’s medical status at least annually.

• The organization will reassign employees who are not physically fit to use a respirator.

• Written instructions that cover the selection and use of the respirators in both normal
operations and emergencies will accompany the respirators.

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• Employees will receive training in the use and limitations of respirators, proper fitting,
and maintenance.

• The organization will schedule respirators for regularly cleaning and disinfection and will
replace defective parts.

• The organization will clean and disinfect any respirator used by more than one person
between uses.

• The facility will conduct routine inspections before and after each use and during clean-
ing. Routine inspection for emergency respirators will take place at least once a month
and after each use.

• Respirators must be properly fitted with a good face seal. Beards, long sideburns, and
glasses may interfere with the fit. Respirators may not be used when such conditions
prevent a good face seal. Physical changes, such as weight gain or loss, may require
refitting of the respirator.

• With corrective lenses and a face piece, a qualified individual should fit for a gas-tight
seal, good vision, and comfort. Wearing contact lenses with a respirator in a contami-
nated atmosphere is prohibited.

• The facility will replace respirator filter cartridges after a specified time, when an
employee can smell vapors in the mask, or if breathing becomes difficult.

• The facility will maintain surveillance of work area conditions and the degrees of
employee exposure or stress.

Head protection (1910.135)


The nature of healthcare workers’ jobs in this facility does not require head protection,
according to OSHA standard 1910.135. If conditions exist requiring head protection, such as
construction work, employees may not enter any areas where head protection is necessary.

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Foot protection (1910.136)


In compliance with OSHA standard 1910.136, occupational foot protection, employees must
wear protective footwear when working in areas where there is a danger of foot injuries due
to falling and rolling objects or objects piercing the sole. Foot protection is also necessary
where employees’ feet may be exposed to electrical hazards. Open-toe shoes are permissible
in locations where no foot hazards exist. Employees must wear shoes that cover the entire
foot when working in areas where exposure to blood, body fluids, contaminated sharps, and
hazardous chemicals spills are possible. Employees must wear safety shoes in locations
where the handling, shipping, or receiving of heavy materials takes place.

Appropriate footwear with good traction should be readily available in delivery rooms and sur-
gical areas to protect against exposure to blood and body fluids.

The organization will perform periodic footwear conductivity checks to minimize the potential
for static electricity in surgical areas.

Hand protection (1910.138)


According to OSHA Standard 1910.138, hand protection, this facility provides appropriate
hand protection—usually gloves—for employees who are exposed to harmful substances or
temperature extremes, or who risk severe cuts, lacerations, abrasions, punctures, chemical
burns, or thermal burns.

Employees routinely use gloves to protect against exposure to blood and other potentially
infectious body fluids. (See Chapter 2 for more information.)

Employees must use hand protection to prevent lacerations from handling objects with sharp
edges, to prevent contact with chemicals, to prevent burns, and to provide shielding from
radiation produced by lasers and other devices. (See Safety precautions for radiation and laser
areas on the next page.)

Selection of the appropriate hand protection complies with the workplace hazard assessment
certification in Figure 4.2, which includes an evaluation of the tasks performed, conditions that
might be present, duration of use, and the chemical hazards and potential hazards of the work.

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Torso and clothing protection


Aprons, leggings, or water-repellant clothing may be necessary for some procedures, depend-
ing on the nature of the hazard.

Hearing protection (1910.95)


Noise levels in this facility do not exceed 85 decibels during an eight-hour day. If conditions
change so that noise exceeds the limit, the employer will provide employees with hearing
protection devices and direct them to wear these devices in accordance with OSHA standard
1910.95, occupational noise exposure.

Safety precautions for radiation and laser areas

Radiation, ionizing and non-ionizing


Employees in healthcare facilities may be exposed to both ionizing and non-ionizing sources
of radiation. Ionizing radiation is produced by such devices as x-ray machines and atomic
accelerators, or by the decay of radioactive material found in radiopharmaceuticals or radioac-
tive medical implants. Devices such as lasers, ultraviolet lamps, ultrasound machines, and
microwave ovens produce non-ionizing radiation. Although ionizing radiation is generally
thought to create the most severe health risks, both types require monitoring.

OSHA and the Nuclear Regulatory Commission (NRC) share responsibility for regulating
worker exposure to radiation. The NRC licenses and regulates the use of radioactive materials,
and OSHA regulations cover the hazards produced by x-ray machines and other types of
atomic accelerators.

Safety precautions for x-ray machines (1910.96, ionizing radiation)


According to OSHA standard 1910.1096, ionizing radiation, and to NIOSH recommendations,
take the following steps be protect employees from exposure to radiation:
• Identify rooms with radiation equipment. Allow only authorized personnel into the area.
Close doors when equipment is in use.

• When portable x-ray units and radioisotopes are in use, allow only the patient and
trained personnel in the room.

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• Locate x-ray controls to prevent the accidental energizing of the machine.

• Check all x-ray machines before each use to confirm that the secondary radiation cones
and filters are in place.

• Wear PPE, such as lead aprons, gloves, and goggles, when working in the direct field or
where scatter radiation levels are high. For procedures where consistently heightened
exposure may occur, such as angioplasty, wear a thyroid shield and leaded glasses.

• Provide medical monitoring in the form of pre-placement and periodic medical examina-
tions for all workers exposed to radiation. Exams should include a complete blood count
and differential white blood count, an eye examination, history of previous radiation
exposure, and a reproductive history.

Safety precautions for non-ionizing radiation (1910.97)


The types of non-ionizing radiation found in healthcare facilities include
• ultraviolet
• visible
• infrared
• radiofrequency or microwave
• ultrasound

The only OSHA standard for non-ionizing radiation applies to electromagnetic radiation origi-
nating from microwave ovens, radio stations, radar equipment, and certain other sources. The
standard does not apply to procedures involving the deliberate exposure to patients by, or
under the direction of, healthcare practitioners.

Microwave radiation has applications in healthcare that include heating in diathermy, can-
cer therapy, thawing frozen organs for transplant, sterilization of ampules, and heating and
cooking food.

Cell damage is the hazard to microwave radiation, and neurological, behavioral, and immuno-

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logical changes are effects usually associated with exposure. The OSHA exposure to
microwave is 10 mW/cm2.

NIOSH recommends monitoring for diathermy equipment leakage before each treatment and
regularly checking microwave ovens for leakage every three months.

Lasers
Lasers are a type of non-ionizing radiation, and the use of lasers in healthcare is increasing.
OSHA does not have a laser standard applying to healthcare, only one that applies to laser
use in the construction industry.

OSHA may issue citations for unsafe working conditions for lasers under its General Duty
Clause 5(a)(1). Such citations may occur if extremely unsafe or unhealthy working condi-
tions exist.

Medical laser systems can present dangerous situations if not used properly. Direct or
reflected beams can harm the eyes and skin of exposed workers. Evidence is accruing that
smoke produced by laser use, called “laser plume,” may contain toxic chemicals and biological
contaminants. Although there are no standards specific to laser plume, the General Duty
Clause, respiratory protection standard 1910.34, and the PPE section of the bloodborne
pathogen standard 1910.1030 touch on these safety hazards.

OSHA’s Web page on laser/electrosurgery plumes, www.osha.gov/SLTC/laserelectrosurgeryplume/


index.html#Compliance, states, “Surgical masks used to prevent contamination of the patient are
not certified for respiratory protection of medical employees.”

The intense heat of a laser can cause fires, and the high-voltage electricity required to power
certain lasers presents a risk of electrical shock.

This facility takes the following steps to protect workers from potential hazards associated
with laser use:
• Appoints a person to be in charge of laser safety, such as the OSHA safety officer or a
special laser safety officer (LSO)

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• Directs the LSO to determine the laser classification (Class I to Class IV) for all lasers in
the facility

• Directs the LSO to establish controls on alignment procedures, limitations on spectators,


standard PPE, laser barriers, and protective curtains

• Creates standard operating procedures, training, and medical surveillance protocols

• Posts hazard-warning signs where lasers are in use or are undergoing maintenance

• Conducts medical testing where required by state laws

Controlling waste anesthetic gases

OSHA has stated that there are hazards associated with the exposure to waste anesthetic
gases that require exposure prevention steps (OSHA Instruction CPL 2-2.20B). The facility may
refer to the manufacturer of the gas to determine the recommended exposure limits.

Operating rooms, dental practices, and recovery rooms are locations where occupational
exposure to waste anesthetic gas may occur. The proper installation and maintenance of a
scavenging system is the fundamental method of controlling worker exposure to waste anes-
thetic gas. A collecting device or scavenging adapter collects the waste gases at the site of
overflow, and a disposal route carries the gases out of the room.

Controls for waste anesthetic gas include the following:


• Leak testing. Check for leaks in the system on a continuing basis. The employer should
inspect and perform schedule maintenance on anesthesia machines at least every four
months with attention to leakage, improper design, tubing defects, wall connections, and
compression fittings. Maintain records of the volume of anesthetic gases used and refer-
ence them as a regular check for leakage.

• Training programs. Implement training programs for all employees involved with waste

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anesthetic gases. Workers should be able to recognize, understand, monitor, and reduce
the health and safety risks of exposure.

• PPE. PPE is not recommended if an acceptable control program is in place. However,


PPE should be available in case of an emergency.

Other methods for removal of waste gases include installing a non-recirculating air-conditioning
system with a minimum of 20 air changes per hour and using low-flow rates of anesthetic gases.

Spill cleanup procedures

Employees can be at risk to exposures when cleaning up spills. Chemical spills involving
glutaraldehyde or mercury from broken medical devices are not uncommon in healthcare
facilities. Cleaning them up requires training and special PPE or equipment. Spills or
cleanup involving blood or other potentially infectious material require specific training
and procedures under the bloodborne pathogen standard.

For chemical spills that occur in this facility do the following:


• Consult the MSDS of the spilled material for warnings, cleanup instructions, and disposal
regulations. Evacuate all persons in the area if dangerous vapors are possible.

• Ask assistance from others to keep patients and personnel away if the chemical is dan-
gerous or if the spill contains blood.

• Put on utility gloves for extra protection from the contents of the spill and put on a respi-
rator mask if the MSDS requires it.

• Contain the spill with paper towels. Apply cat litter or other material to absorb the spill.

• Continue to put more absorber onto the spill if necessary to convert the liquid into a
manageable solid material.

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• Scoop the solid material into a waste container or sealed bag, depending on the MSDS
disposal instructions. Dispose outside if the material is noxious.

This facility has prepared a spill kit containing (at least) these items:
• A container or box labeled “spill kit”
• Utility gloves
• Absorbing material (a coffee can sized amount of cat litter)
• Paper towels
• A dust pan and brush to scoop the material
• An available tuberculocidal disinfectant for blood spills

Glutaraldehyde spill cleanup procedure


Prior to working with glutaraldehyde, employees should undergo training in its proper use
and spill cleanup procedures. Have a neutralizing agent on site in case of a spill emergency.
Always consult the MSDS for specific spill procedures and disposal instructions.

Spills of less than 1 gal


In the event of a small glutaraldehyde spill, evacuate the area immediately. Only those per-
sons who will be involved in the actual cleanup of the spill should come into contact with the
chemical. Consult the MSDS spill instructions and refer to them during cleanup.

Don the appropriate PPE. It must include, but not be limited to, eye and face protection;
impervious gloves (nitrile or butyl rubber gloves are recommended by the Association for
Advancement of Medical Instrumentation); full-length, glutaraldehyde-impervious clothing;
impervious shoe protection; a glutaraldehyde spill kit; and a NIOSH-approved respirator.

Contain the liquid with an absorbent material, such as cat litter. Using a dustpan, scoop
the material into a trash bag. Mop or wipe the area with clean water to reduce the levels of
glutaraldehyde on the surface. Completely remove the glutaraldehyde from the area, and
ventilate as needed.

After appropriately containing the spill, dispose of the contaminated equipment and absorbed
material according to appropriate federal, state, and local regulations.

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Spills of more than 1 gal


Follow the steps written above, with these modifications:
• Don a full-face, air-purifying respirator with organic vapor cartridges. If the spill is
exceptionally large, or the vapors are intense, isolate the area. Obtain help from the fire
department if necessary.

• Use a glutaraldehyde-neutralizing agent, such as one-half ammonia and one-half water,


or a glutaraldehyde neutralizer to inactivate the glutaraldehyde spill. Follow the manufac-
turer’s MSDS for specific directions.

Mercury spills
The vapor from broken mercury-containing devices, such as thermometers or sphygmo-
manometers, poses a hazard to workers and patients in a healthcare facility. The physical
properties of mercury make the spill difficult to contain, which could lead to contamination
beyond the site of the spill, such as on shoes and into carpeting in other areas of the facility.
Therefore, employees who handle mercury-containing equipment should receive training in
emergency procedures and responses to spilled mercury. A written, immediately accessible,
mercury-spill response should provide cleanup procedures, PPE, and respirator requirements.
Mercury spill kits appropriate for the size of the potential spill should be available for the
emergency.

Other recommendations include the following:


• Clean up spills with a special mercury vacuum cleaner. Never use a regular household
vacuum cleaner or workshop wet vacuum cleaner.

• Wear disposable PPE and respirators.

• Wash hands and skin thoroughly. Don’t eat, drink, or apply lip balm when handling mercury.

• Post signs and warnings about the spill site, and eliminate access. Remove patients and
workers from the area.

• Use a mercury “sniffer” to determine whether cleanup is complete.

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Recycle or dispose of mercury waste in accordance with Environmental Protection Agency reg-
ulations (40 CFR 261.24) and state programs or regulations for mercury use and release.
Contact the appropriate state environmental office for more information regarding mercury
regulations in your state (www.epa.gov/epahome/state.htm).

Mercury spill tip: If there is a small mercury spill—no larger than thermometer size—and a
spill kit is not available, treat the spill with hairspray to harden the mercury beads. Then
sweep up the spill, place it and all devices used in a plastic bag, and discard it according to
state mercury waste disposal regulations.

Medical and first aid instruction

Employers who do not have immediate access to an infirmary, clinic, or hospital are sub-
ject to OSHA’s general industry standard for medical and first aid treatment. “Immediate
access” means within a 15-minute drive to a hospital or emergency care facility. OSHA
standard 1910.151 requires that employers provide appropriate first aid training and sup-
plies for use in the event of an emergency. This facility maintains adequate coverage of
these requirements.

General requirements
Facilities that do not have access (within 15 minutes from the workplace) to an infirmary,
clinic, or hospital must comply with the following minimum first aid requirements:
• At least one, and preferably more, employees on each shift must receive training to ren-
der first aid. The American Red Cross, some insurance carriers, local safety councils, and
other programs provide acceptable training.

• First aid supplies must be readily available in sanitary containers with individually
sealed, sterile packages for materials such as gauze, bandages, and dressings. Other
items often needed are adhesive tape, triangular bandages for slings, inflatable plastic
splints, scissors, and mild soap for cleansing wounds or cuts. The Red Cross and some
medical supply firms have suggestions for the kinds and amounts of first aid supplies
according to practice size.

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• Suitable facilities for flushing the eyes and body must be provided within any work area
where workers may face exposure to chemicals or corrosive materials.

Some states have laws concerning medical practices that establish limits on first aid given by
a layperson. Trained employees should learn from their trainers where first aid ends and med-
ical treatment begins.

Training guidelines
OSHA does not certify first aid training courses, but it has published OSHA Instruction CPL 2-
2.53 for employers to use in developing their programs. The following is a list of the basic and
essential elements of this guideline. General elements of a first aid training program should
include provision for the following:
• Health and emergency response

• Emergency situation assessment

• Adult cardiopulmonary resuscitation

• Basic first aid intervention

• Maintenance of appropriate supplies

• Instruction on treating shock, bleeding, poisoning, burns, temperature extremes, muscu-


loskeletal injuries, bites and stings, and medical emergencies such as heart attacks,
strokes, and seizures

• Administration of first aid in confined spaces

The instruction should include first aid intervention for injuries to the head and neck, eyes,
nose, mouth and teeth, chest, abdomen, and extremities.

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Cardiopulmonary resuscitation (CPR)


According to the American Red Cross, most cardiac fatalities occur when medical help is not
immediately available. Many fatalities could have been prevented if the person received basic
life support/emergency first aid in the first few seconds after cardiac arrest. Local Red Cross
chapters can provide information on the locations of CPR training classes.

Recordkeeping

This facility’s safety officer maintains the records for all employee exposures, employee med-
ical records, and analysis of those records. To maintain employee confidentiality, this facility
keeps these records separate from the employees’ personnel files in a locked area.

This facility keeps these records, with the exceptions listed below, on file for the duration of
employment plus 30 years. Exceptions include
• health insurance claims maintained separately from the employer’s medical program and
its records.

• first aid records—excluding medical histories—of one-time treatment of minor scratches,


cuts, burns, splinters, etc., that do not require medical treatment or involve loss of con-
sciousness, restriction of work, or motion or transfer to another job.

• records for employees who have worked for less than one year for the employer. The
employee will receive his or her records upon termination of employment.

Whenever an employee (or designated representative) requests access to records, this


employer will provide access in a reasonable time, place, and manner, and will try to give
access within 15 days. The organization will provide the first copy of the records at no cost.
For additional copies, the employer may charge a reasonable fee.

If the above guidelines are not possible, this employer will let the employee know the reason
for the delay and the earliest day when the records will be available.

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Injury documentation following a chemical exposure


Whenever an injury occurs in this facility, the following documents need to be completed (see
Chapter 4 for the location of these forms):
• Employee exposure incident form. This form documents the circumstances of the expo-
sure, route of exposure, and status of post-exposure, if applicable.

• Employee informed refusal of a medical evaluation after an accident (other than a


bloodborne pathogen exposure). Complete the form if the employee chooses to not
undergo a post-exposure evaluation. Document the refusal for the protection of the
employer.

• Accident investigation report. This report helps prevent the same type of accident from
recurring. At a minimum, the report should contain the injured employee’s name, age,
occupation, and months on the job; who conducted the investigation; the date investi-
gated; who reviewed the investigation; the date of the review; the date and time, location,
and description of the incident; description of the injuries or damage; description of the
unsafe conditions that contributed to the accident; and recommendations and corrective
actions taken regarding the incident.

• OSHA Form 300. Even though most practices are exempt from filling out this form, it is
recommended to complete it for your own records.

Medical evaluation following a chemical exposure


If the incident requires treatment by a third-party healthcare professional, the facility will pro-
vide the following to the professional:
• A copy of the OSHA standard relevant to the exposure
• A description of the employee’s duties as they relate to the exposure incident
• A photocopy of the employee exposure incident form

All records generated by the third-party healthcare professional shall be filed with the
employee’s confidential records.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 37


C HAPTER 1—H AZARD COMMUNICATION POLICY

OSHA sources of information for this section


• Access to employee exposure and medical records, 1910.1020
• Eye and face protection, 29 CFR 1910.133
• General requirements, 29 CFR 1910.132
• Hand protection, 29 CFR 1910.138
• Hazard communication standard, 29 CFR 1910.1200
• Hazardous drug standard, OSHA Instruction CPL 2-2.20B (April 14, 1995)
• Head protection, 29 CFR 1910.135
• Ionizing radiation, 29 CFR 1910.1096
• Medical services and first aid, 29 CFR 1910.151
• Non-ionizing radiation, 29 CFR 1910.97
• Occupational foot protection, 29 CFR 1910.136
• Occupational noise exposure, 29 CFR 1910.95
• Respiratory protection standard, 29 CFR 1910.134
• Ventilation, 29 CFR 1910.94

38 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.3 Target organ effects

OSHA requires
OSHA requires thethe identification
identification of organ
of target targeteffects
organoneffects onThe
the label. thefollowing
label. The
is afollowing
list of
effects, which could occur from toxic chemicals.
is a list of effects that could occur from toxic chemicals.

Chemical Target organ

Hepatotoxins Chemicals that produce liver damage


Signs and symptoms: Jaundice, liver enlargement
Example(s): Nitrosamines

Nephrotoxins Chemicals that produce kidney damage


Signs and symptoms: Edema, proteinuria
Example(s): Halogenated hydrocarbons, uranium

Neurotoxins Chemicals that produce their primary toxic effects on the


nervous system
Signs and symptoms: Narcosis, behavioral changes, decrease in
motor functions
Example(s): Mercury

Agents that damage the lungs Chemicals that irritate or damage the pulmonary tissue
Signs and symptoms: Cough, tightness in chest, shortness of
breath
Example(s): Silica, asbestos

Reproductive toxins Chemicals that affect the reproductive capabilities, including


chromosomal damage (mutations) and effects on fetuses
(teratogenesis)
Signs and symptoms: Birth defects, sterility
Example(s): Lead, DBCP
Agents that act on the blood or Chemicals that decrease hemoglobin function and deprive the
hemato-poietic system body tissues of oxygen
Signs and symptoms: Cyanosis, loss of consciousness
Example(s): Monoxide, cyanides

Cutaneous hazards Chemicals that affect the dermal layer of the body (skin)
Signs and symptoms: Defatting of the skin, rashes, irritation
Example(s): Ketones, chlorinated compounds

Eye hazards Chemicals that affect the eye or visual capacity


Signs and symptoms: Conjunctivitis, corneal damage
Example(s): Organic solvents, acids

For more signs and symptoms and a representative list of chemicals, refer to OSHA’s hazard
communication standard, health hazard definitions—1910.1200, in Chapter 1.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 39


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.4 Glossary of terms


These definitions are appropriate to a healthcare facility. Additional definitions are in the
complete copy of the hazard communication standard on file with the safety officer.

Chemical: An element, chemical compound, or mixture thereof.

Chemical name: A name developed by the Chemical Abstracts Service that clearly identifies a
chemical.

Chemical liquid: A liquid with a flash point between 100° F and 200° F.

Common name: The brand name, generic name, or trade name, other than the chemical name,
used to identify a chemical.

Compressed gas: A gas mixture that exceeds 40 psi at 70° F.

Explosive: A chemical that causes a sudden release of pressure, gas, and heat when subjected to
shock, pressure, or heat.

Exposure: The subjection of a worker to a hazardous chemical through inhalation, ingestion, or


other contact.

Flammable: Aerosol flammable is a substance that will yield a flame 18 in or more at full valve
opening. Gas flammable is a gas that forms a flammable mixture when mixed 13% or less with
air. Liquid flammable is a liquid with a flash point below 100° F. Solid flammable is a solid that
will ignite and burn with a self-sustained flame so vigorously as to create a serious hazard.

Flash point: The temperature at which the vapor from a liquid will ignite when exposed to a
flame.

Hazardous chemical: A chemical that could injure the worker.

Hazard warning: Pictures, words, or symbols that convey a warning of the hazards of the
chemicals in the containers.

Identity: The chemical or brand name of a substance. It is used to cross-reference the material
between the material safety data sheet, the label, and the Hazardous chemical substance list.

Physical hazard: A substance that presents a potential danger, such as a compressed gas or
liquid; explosive or flammable substance; organic peroxide; oxidizer (i.e., capable of causing
fires); pyrophoric (i.e., ignites spontaneously at or below 130° F) substance; substance unstable
to pressure, shocks, or temperature; or water reactive substance (i.e., reacts to water to form a
dangerous gas or hazard).

Work area: A defined space in the workplace where hazardous chemicals are used and where
employees are present.

40 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.5 Occupational hazards by location in healthcare facilities

Central supply Solvents Tools, machinery Electrical


Ethylene oxide Disinfectants Noise Sharp instruments
Infection Glutaraldehyde Welding fumes Lifting
Broken equipment (cuts) Infection Asbestos
Soaps, detergents Needle punctures Flammable liquids Pathology
Steam Wastes (chemical, radioactive, Solvents Infectious disease
Flammable gases infectious) Mercury Formaldehyde
Lifting Electrical hazards Pesticides Glutaraldehyde
Noise Lifting Cleaners Flammable substances
Mercury Climbing Ammonia Freons
Slips, falls Carbon monoxide Solvents
Dental service Laboratory Ethylene oxide Phenols
Mercury Infectious diseases Freons
Ethylene oxide Toxic chemicals Paints, adhesives
Anesthetic gases Benzene Patient care
Water treatment chemicals Lifting
Ionizing radiation Ethylene oxide
Sewage Pushing, pulling
Infection Formaldehyde
Heat stress Slips, falls
Solvents
Cold stress (refrigeration units) Standing for long periods
Dialysis units Flammable and explosive
Infection agents Falls Infectious disease
Formaldehyde Carcinogens Lifting Needle punctures
Teratogens Climbing Toxic substances
Food service Mutagens Strains and sprains Chemotherapeutic agents
Wet floors Cryogenic hazards Radiation
Sharp equipment Wastes (chemical, radioactive, Nuclear medicine Radioactive patients
Noise infectious) Radionuclides Electrical hazards
Soaps, detergents Radiation Infection
Disinfectants X-irradiation Pharmacy
Ammonia Laundry Office areas and data Pharmaceuticals
Chlorine Wet floors Processing Antineoplastic agents
Solvents Lifting Video display terminals Mercury
Drain cleaners Noise Air quality Slips, falls
Oven cleaners Heat Ergonomics/body mechanics
Caustic solutions Burns
Chemicals Print shops
Pesticides Infection
Ozone Inks
Microwave ovens Needle punctures
Hostile persons Solvents
Steam lines Detergents, soaps
Ovens Bleaches Noise
Heat Solvents Operating rooms Fire
Electrical hazards Wastes (chemical and Anesthetics
Lifting radioactive) Antiseptics Radiology
Methyl methacrylate Radiation
Housekeeping Maintenance and Compressed gases Infectious diseases
Soaps, detergents engineering Sterilizing gases Lifting
Cleaners Electrical hazards Infection Pushing, pulling

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 41


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.6 Hazard communication compliance check-off list

The safety officer can use this check-off list to ensure compliance with commonly overlooked
hazard communication standard items. Chapter 1 contains a copy of the 1994 standard.
Items with an *asterisk are in compliance if you are in possession of the Medical Environment
program.

Section Requirements 2005 2006 2007 2008


1910.1200 Program, labels, and material safety data sheet (MSDS) administration
(e)(1) *The program is in writing.
(f) *The labeling system is described.
(e)(i) A physical inventory of hazardous chemicals was
performed and is reviewed annually.
(h) *The hazard communication training system is
described.
(e)(4) The written program is available to all employees.
(f)(6) Stationary containers, such as sterilizing trays
(“boats”), for instruments, are labeled.
(f)(5)(ii) Labels are complete, accurate, and legible.
(f)(1) Labels contain both the brand name and the chemical
name, and both coincide with the MSDS.
(f)(9) Labels are legible and written in English.
(f)(5)(ii) Labels identify the immediate and direct
consequences of mishandling.
(f)(1)(iii) Labels include the name and address of the chemical
manufacturer.
(f)(5) Labels on containers that are away from the original
(f)(7) container identify the chemical name, the brand
name, the manufacturer, the immediate hazard, and
the target organs, unless intended for immediate use.
(g)(1) An MSDS is available for every hazardous chemical
used. MSDSs should be in alphabetical order by
brand name (or chemical name, if the facility
wishes). Any system is authorized if it works for the
facility.
(g)(8) MSDSs are readily accessible to all potentially
exposed employees in the work area.

42 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.6 Hazard communication compliance check-off list (cont.)

Section Requirements 2005 2006 2007 2008


1910.1200 Program, labels, and MSDS administration
(g)(5)
MSDSs receive an annual review for accuracy and
(h)(i)
the correct product. MSDS training is performed for
new employees before exposure to any chemicals.

(h) Both permanent and temporary employees are


advised of any MSDS changes and MSDSs for new
products.
Training
(h)(1) *Employees have received instructions about the
requirements of the hazard communication standard.

(h)(2)(iii) Employees are aware of the location of the MSDSs


and the written hazard communication program.
(h)(2)(ii) Training includes physical and health hazards of
chemicals in the work area.
(h)(3)(i) On-site training is given in detecting the presence of
hazardous materials (e.g., peculiar smells of
glutaraldehydes, gases, electrical fires, etc.).
(h)(3)(iii) Training in the proper use and selection of personal
protective equipment (PPE) as noted on the MSDS is
provided.
(h)(3)(iii) Emergency procedures noted on the MSDS are
reviewed, including spill cleanup.
(h)(2)(iii) How to find employee health and safety information
in the MSDS (usually Section V to VIII) is covered.
(h)(3)(iii) How employees can protect themselves is covered.
(h) On-the-spot training for employees only temporarily
doing work around MSDS chemicals is provided.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 43


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.6 Hazard communication compliance check-off list (cont.)

29 CFR Eye and face protection is afforded in areas where


1910.132- hazards exist.
140
29 CFR Goggles, protective glasses, and respirators fit the
1910.132- individual wearing them.
140
29 CFR Disposable shoe covers are available in delivery
1910.132- rooms and surgical areas.
140
29 CFR Slip-resistant footwear is worn around wet floors.
1910.132-
140
29 CFR Respirators are provided when necessary; written
1910.132- operating procedures are provided for respirators.
140
Ventilation
29 CFR Ventilation systems are effective at removing toxic
1910.106 dust, vapors, and gases from the working
environment.

29 CFR Hoods are used to exhaust contaminants out of the


1910.106 work area.
29 CFR Chemicals such as glutaraldehydes and acetones are
1910.106 used only in well-ventilated areas.
Noise
29 CFR Suitable hearing protection is worn in a noisy
1910.95 environment.

29 CFR Noise does not exceed 90 dBA in any area during an


1910.95 eight-hour workday.
Medical/first aid
29 CFR First aid supplies are available, inspected,
1910.151 replenished, and complete.
Subpart J

29 CFR A person trained in first aid is available on each shift.


1910.151
Subpart J
29 CFR
Emergency phone numbers are posted.
1910.151
Subpart J

44 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.6 Hazard communication compliance check-off list (cont.)

Section Requirements 2005 2006 2007 2008


Miscellaneous
CPL 2- The hazardous-drug plan is accessible to all
2.20B employees.
1910.141 All waste containers are emptied regularly and are
sanitary.
1910.141 Toilets are provided at a ratio of one per 15
employees and are sanitary.
1910.141 Eating is prohibited in areas exposed to toxic
materials or toilets.
1910.141 Each toilet area has hot (or at least tepid) and cold
water, hand soap, and individual hand towels or air
blowers.
ANSI Eyewash stations are within 10 seconds from use of
Z358.1- blood and toxic chemicals.
1990
1910.303 There is adequate lighting in work areas.
1910.141 Water that is used for drinking, washing, and cooking
is suitable for drinking.
1910.141 Pest control is in operation, if necessary.
1910.253 Steam pipes and hot surfaces are insulated or guarded
from employee exposure, and the direction of flow is
clearly marked on the pipes.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 45


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200

1910.1200(a) general guide for such employers to shipments of the sealed containers of
"Purpose." help them determine their hazardous chemicals, shall obtain a
1910.1200(a)(1) compliance obligations under the material safety data sheet as soon as
The purpose of this section is to ensure rule.) possible for sealed containers of hazardous
that the hazards of all chemicals produced 1910.1200(b)(2) chemicals received without a material
or imported are evaluated, and that This section applies to any chemical safety data sheet if an employee requests
information concerning their hazards is which is known to be present in the the material safety data sheet, and shall
transmitted to employers and employees. workplace in such a manner that ensure that the material safety data sheets
This transmittal of information is to be employees may be exposed under are readily accessible during each work
accomplished by means of comprehensive normal conditions of use or in a shift to employees when they are in their
hazard communication programs, which foreseeable emergency. work area(s); and,
are to include container labeling and other 1910.1200(b)(3) 1910.1200(b)(4)(iii)
forms of warning, material safety data This section applies to laboratories Employers shall ensure that employees are
sheets and employee training. only as follows: provided with information and training in
1910.1200(a)(2) 1910.1200(b)(3)(i) accordance with paragraph (h) of this
This occupational safety and health Employers shall ensure that labels on section (except for the location and
standard is intended to address incoming containers of hazardous availability of the written hazard
comprehensively the issue of evaluating chemicals are not removed or communication program under paragraph
the potential hazards of chemicals, and defaced; (h)(2)(iii) of this section), to the extent
communicating information concerning 1910.1200(b)(3)(ii) necessary to protect them in the event of a
hazards and appropriate protective Employers shall maintain any spill or leak of a hazardous chemical from
measures to employees, and to preempt material safety data sheets that are a sealed container.
any legal requirements of a state, or received with incoming shipments of 1910.1200(b)(5)
political subdivision of a state, pertaining hazardous chemicals, and ensure that This section does not require labeling of
to this subject. Evaluating the potential they are readily accessible during the following chemicals:
hazards of chemicals, and communicating each workshift to laboratory 1910.1200(b)(5)(i)
information concerning hazards and employees when they are in their Any pesticide as such term is defined in
appropriate protective measures to work areas; the Federal Insecticide, Fungicide, and
employees, may include, for example, but 1910.1200(b)(3)(iii) Rodenticide Act (7 U.S.C. 136 et seq.),
is not limited to, provisions for: Employers shall ensure that when subject to the labeling requirements
developing and maintaining a written laboratory employees are provided of that Act and labeling regulations issued
hazard communication program for the information and training in under that Act by the Environmental
workplace, including lists of hazardous accordance with paragraph (h) of this Protection Agency;
chemicals present; labeling of containers section, except for the location and 1910.1200(b)(5)(ii)
of chemicals in the workplace, as well as availability of the written hazard Any chemical substance or mixture as
of containers of chemicals being shipped communication program under such terms are defined in the Toxic
to other workplaces; preparation and paragraph (h)(2)(iii) of this section; Substances Control Act (15 U.S.C. 2601 et
distribution of material safety data sheets and, seq.), when subject to the labeling
to employees and downstream employers; 1910.1200(b)(3)(iv) requirements of that Act and labeling
and development and implementation of Laboratory employers that ship regulations issued under that Act by the
employee training programs regarding hazardous chemicals are considered Environmental Protection Agency;
hazards of chemicals and protective to be either a chemical manufacturer 1910.1200(b)(5)(iii)
measures. Under section 18 of the Act, no or a distributor under this rule, and Any food, food additive, color additive,
state or political subdivision of a state may thus must ensure that any containers drug, cosmetic, or medical or veterinary
adopt or enforce, through any court or of hazardous chemicals leaving the device or product, including materials
agency, any requirement relating to the laboratory are labeled in accordance intended for use as ingredients in such
issue addressed by this Federal standard, with paragraph (f)(1) of this section, products (e.g. flavors and fragrances), as
except pursuant to a Federally-approved and that a material safety data sheet such terms are defined in the Federal
state plan. is provided to distributors and other Food, Drug, and Cosmetic Act (21 U.S.C.
1910.1200(b) employers in accordance with 301 et seq.) or the Virus-Serum-Toxin Act
"Scope and application." paragraphs (g)(6) and (g)(7) of this of 1913 (21 U.S.C. 151 et seq.), and
1910.1200(b)(1) section. regulations issued under those Acts, when
This section requires chemical 1910.1200(b)(4) they are subject to the labeling
manufacturers or importers to assess the In work operations where employees requirements under those Acts by either
hazards of chemicals which they produce only handle chemicals in sealed the Food and Drug Administration or the
or import, and all employers to provide containers which are not opened Department of Agriculture;
information to their employees about the under normal conditions of use (such 1910.1200(b)(5)(iv)
hazardous chemicals to which they are as are found in marine cargo Any distilled spirits (beverage alcohols),
exposed, by means of a hazard handling, warehousing, or retail wine, or malt beverage intended for non-
communication program, labels and other sales), this section applies to these industrial use, as such terms are defined in
forms of warning, material safety data operations only as follows: the Federal Alcohol
sheets, and information and training. In 1910.1200(b)(4)(i) Administration Act (27 U.S.C. 201 et
addition, this section requires distributors Employers shall ensure that labels on seq.) and regulations issued under that
to transmit the required information to incoming containers of hazardous Act, when subject to the labeling
employers. (Employers who do not chemicals are not removed or requirements of that Act and labeling
produce or import chemicals need only defaced; regulations issued under that Act by the
focus on those parts of this rule that deal 1910.1200(b)(4)(ii) Bureau of Alcohol, Tobacco, and
with establishing a workplace program and Employers shall maintain copies of Firearms;
communicating information to their any material safety data sheets that 1910.1200(b)(5)(v)
workers. Appendix E of this section is a are received with incoming

46 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)

Any consumer product or hazardous cosmetics intended for personal 31:9102


substance as those terms are defined in the consumption by employees while in mixture having components with
Consumer Product Safety Act (15 U.S.C. the workplace; flashpoints of 200 deg. F (93.3 deg. C), or
2051 et seq.) and Federal Hazardous 1910.1200(b)(6)(ix) higher, the total volume of which make up
Substances Act (15 U.S.C. 1261 et seq.) Any consumer product or hazardous 99 percent or more of the total volume of
respectively, when subject to a consumer substance, as those terms are defined the mixture.
product safety standard or labeling in the Consumer Product Safety Act "Commercial account" means an
requirement of those Acts, or regulations (15 U.S.C. 2051 et seq.) and Federal arrangement whereby a retail distributor
issued under those Acts by the Consumer Hazardous Substances Act (15 sells hazardous chemicals to an employer,
Product Safety Commission; and, U.S.C. 1261 et seq.) respectively, generally in large quantities over time
1910.1200(b)(5)(vi) where the employer can show that it and/or at costs that are below the regular
Agricultural or vegetable seed treated with is used in the workplace for the retail price.
pesticides and labeled in accordance with purpose intended by the chemical "Common name" means any designation
the Federal Seed Act (7 U.S.C. 1551 et manufacturer or importer of the or identification such as code name, code
seq.) and the labeling regulations issued product, and the use results in a number, trade name, brand name or
under that Act by the Department of duration and frequency of exposure generic name used to identify a chemical
Agriculture. which is not greater than the range of other than by its chemical name.
1910.1200(b)(6) exposures that could reasonably be "Compressed gas" means:
This section does not apply to: experienced by consumers when (i) A gas or mixture of gases having, in a
1910.1200(b)(6)(i) used for the purpose intended; container, an absolute pressure exceeding
Any hazardous waste as such term is 1910.1200(b)(6)(x) 40 psi at 70 deg. F (21.1 deg. C); or
defined by the Solid Waste Disposal Act, Nuisance particulates where the (ii) A gas or mixture of gases having, in a
as amended by the Resource Conservation chemical manufacturer or importer container, an absolute pressure exceeding
and Recovery Act of 1976, as amended can establish that they do not pose 104 psi at 130 deg. F (54.4 deg. C)
(42 U.S.C. 6901 et seq.), when subject to any physical or health hazard regardless of the pressure at 70 deg. F
regulations issued under that Act by the covered under this section; (21.1 deg. C); or
Environmental Protection Agency; 1910.1200(b)(6)(xi) (iii) A liquid having a vapor pressure
1910.1200(b)(6)(ii) Ionizing and nonionizing radiation; exceeding 40 psi at 100 deg. F (37.8 deg.
Any hazardous substance as such term is and, C) as determined by ASTM D-323-72.
defined by the Comprehensive 1910.1200(b)(6)(xii) "Container" means any bag, barrel,
Environmental Response, Compensation Biological hazards. bottle, box, can, cylinder, drum, reaction
and Liability ACT (CERCLA) (42 U.S.C. 1910.1200(c) vessel, storage tank, or the like that
9601 et seq.) when the hazardous "Definitions." contains a hazardous chemical. For
substance is the focus of remedial or "Article" means a manufactured purposes of this section, pipes or piping
removal action being conducted under item other than a fluid or particle: (i) systems, and engines, fuel tanks, or other
CERCLA in accordance with the which is formed to a specific shape operating systems in a vehicle, are not
Environmental Protection Agency or design during manufacture; (ii) considered to be containers.
regulations. which has end use function(s) "Designated representative" means any
1910.1200(b)(6)(iii) dependent in whole or in part upon individual or organization to whom an
Tobacco or tobacco products; its shape or design during end use; employee gives written authorization to
1910.1200(b)(6)(iv) and (iii) which under normal exercise such employee's rights under this
Wood or wood products, including lumber conditions of use does not release section. A recognized or certified
which will not be processed, where the more than very small quantities, e.g., collective bargaining agent shall be treated
chemical manufacturer or importer can minute or trace amounts of a automatically as a designated
establish that the only hazard they pose to hazardous chemical (as determined representative without regard to written
employees is the potential for flammability under paragraph (d) of this section), employee authorization.
or combustibility (wood or wood products and does not pose a physical hazard "Director" means the Director, National
which have been treated with a hazardous or health risk to employees. Institute for Occupational Safety and
chemical covered by this standard, and "Assistant Secretary" means the Health, U.S. Department of Health and
wood which may be subsequently sawed Assistant Secretary of Labor for Human Services, or designee.
or cut, generating dust, are not exempted); Occupational Safety and Health, "Distributor" means a business, other
1910.1200(b)(6)(v) U.S. Department of Labor, or than a chemical manufacturer or importer,
Articles (as that term is defined in designee. which supplies hazardous chemicals to
paragraph (c) of this section); "Chemical" means any element, other distributors or to employers.
1910.1200(b)(6)(vi) chemical compound or mixture of "Employee" means a worker who may be
Food or alcoholic beverages which are elements and/or compounds. exposed to hazardous chemicals under
sold, used, or prepared in a retail "Chemical manufacturer" means normal operating conditions or in
establishment (such as a grocery store, an employer with a workplace where foreseeable emergencies. Workers such as
restaurant, or drinking place), and foods chemical(s) are produced for use or office workers or bank tellers who
intended for personal consumption by distribution. encounter hazardous chemicals only in
employees while in the workplace; "Chemical name" means the non-routine, isolated instances are not
1910.1200(b)(6)(vii) scientific designation of a chemical covered.
Any drug, as that term is defined in the in accordance with the nomenclature "Employer" means a person engaged in a
Federal Food, Drug, and Cosmetic Act system developed by the business where chemicals are either used,
(21 U.S.C. 301 et seq.), when it is in solid, International Union of Pure and distributed, or are produced for use or
final form for direct administration to the Applied Chemistry (IUPAC) or the distribution, including a contractor or
patient (e.g., tablets or pills); drugs which Chemical Abstracts Service (CAS) subcontractor.
are packaged by the chemical rules of nomenclature, or a name "Explosive" means a chemical that causes
manufacturer for sale to consumers in a which will clearly identify the a sudden, almost instantaneous release of
retail establishment (e.g., over-the-counter chemical for the purpose of pressure, gas, and heat when subjected to
drugs); and drugs intended for personal conducting a hazard evaluation. sudden shock, pressure, or high
consumption by employees while in the "Combustible liquid" means any temperature.
workplace (e.g., first aid supplies); liquid having a flashpoint at or above "Exposure or exposed" means that an
1910.1200(b)(6)(viii) 100 deg. F (37.8 deg. C), but below employee is subjected in the course of
Cosmetics which are packaged for sale to 200 deg. F (93.3 deg. C), except any employment to a chemical that is a
consumers in a retail establishment, and physical or health hazard, and includes

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 47


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


S-290
potential (e.g. accidental or possible) are excluded from any of the 31:9103
exposure. "Subjected" in terms of health flashpoint determination methods chemicals.
hazards includes any route of entry (e.g. specified above. "Material safety data sheet (MSDS)"
inhalation, ingestion, skin contact or "Foreseeable emergency" means means written or printed material
absorption.) any potential occurrence such as, but concerning a hazardous chemical which is
"Flammable" means a chemical that falls not limited to, equipment failure, prepared in accordance with paragraph (g)
into one of the following categories: rupture of containers, or failure of of this section.
(i) "Aerosol, flammable" means an aerosol control equipment "Mixture" means any combination of two
that, when tested by the method described which could result in an uncontrolled or more chemicals if the combination is
in 16 CFR 1500.45, yields a flame release of a hazardous chemical into not, in whole or in
projection exceeding 18 inches at full the workplace. part, the result of a chemical reaction.
valve opening, or a flashback (a flame "Hazardous chemical" means any "Organic peroxide" means an organic
extending back to the valve) at any degree chemical which is a physical hazard compound that contains the bivalent -O-O-
of valve opening; or a health hazard. structure and which may be considered to
(ii) "Gas, flammable" means: (A) A gas "Hazard warning" means any be a structural derivative of hydrogen
that, at ambient temperature and pressure, words, pictures, symbols, or peroxide where one or both of the
forms a flammable mixture with air at a combination thereof appearing on a hydrogen atoms has been replaced by an
concentration of thirteen (13) percent by label or other appropriate form of organic radical.
volume or less; or warning which convey the specific "Oxidizer" means a chemical other than a
(B) A gas that, at ambient temperature and physical and health hazard(s), blasting agent or explosive as defined in
pressure, forms a range of flammable including target organ effects, of the 1910.109(a), that initiates or promotes
mixtures with air wider than twelve (12) chemical(s) in the container(s). (See combustion in other materials, thereby
percent by volume, regardless of the lower the definitions for "physical hazard" causing fire either of itself or through the
limit; and "health hazard" to determine the release of oxygen or other gases.
(iii) "Liquid, flammable" means any hazards which must be covered.) "Physical hazard" means a chemical for
liquid having a flashpoint below 100 deg. "Health hazard" means a chemical which there is scientifically valid evidence
F (37.8 deg. C), except any mixture having for which there is statistically that it is a combustible liquid, a
components with flashpoints of 100 deg. F significant evidence based on at least compressed gas, explosive, flammable, an
(37.8 deg. C) or higher, the total of which one study conducted in accordance organic peroxide, an oxidizer, pyrophoric,
make up 99 percent or more of the total with established scientific principles unstable (reactive) or water-reactive.
volume of the mixture. that acute or chronic health effects "Produce" means to manufacture,
(iv) "Solid, flammable" means a solid, may occur in exposed employees. process, formulate, blend, extract,
other than a blasting agent or explosive as The term "health hazard" includes generate, emit, or repackage.
defined in 1910.109(a), that is liable to chemicals which are carcinogens, "Pyrophoric" means a chemical that will
cause fire through friction, absorption of toxic or highly toxic agents, ignite spontaneously in air at a
moisture, spontaneous chemical change, or reproductive toxins, irritants, temperature of 130 deg. F (54.4 deg. C) or
retained heat from manufacturing or corrosives, sensitizers, hepatotoxins, below.
processing, or which can be ignited readily nephrotoxins, neurotoxins, agents "Responsible party" means someone
and when ignited burns so vigorously and which act on the hematopoietic who can provide additional information on
persistently as to create a serious hazard. system, and agents which damage the hazardous chemical and appropriate
A chemical shall be considered to be a the lungs, skin, eyes, or mucous emergency procedures, if necessary.
flammable solid if, when tested by the membranes. Appendix A provides "Specific chemical identity" means the
method described in 16 CFR 1500.44, it further definitions and explanations chemical name, Chemical Abstracts
ignites and burns with a self-sustained of the scope of health hazards Service (CAS) Registry Number, or any
flame at a rate greater than one-tenth of an covered by this section, and other information that reveals the precise
inch per second along its major axis. Appendix B describes the criteria to chemical designation of the substance.
"Flashpoint" means the minimum be used to determine whether or not "Trade secret" means any confidential
temperature at which a liquid gives off a a chemical is to be considered formula, pattern, process, device,
vapor in sufficient concentration to ignite hazardous for purposes of this information or compilation of information
when tested as follows: standard. that is used in an employer's business, and
(i) Tagliabue Closed Tester (See American "Identity" means any chemical or that gives the employer an opportunity to
National Standard Method of Test for common name which is indicated on obtain an advantage over competitors who
Flash Point by Tag Closed the material safety data sheet do not know or use it.
Tester, Z11.24-1979 (ASTM D 56-79)) for (MSDS) for the chemical. The Appendix D sets out the criteria to be used
liquids with a viscosity of less than 45 identity used shall permit cross- in evaluating trade secrets.
Saybolt Universal Seconds (SUS) at references to be made among the "Unstable (reactive)" means a chemical
100 deg. F (37.8 deg. C), that do not required list of hazardous chemicals, which in the pure state, or as produced or
contain suspended solids and do not the label and the MSDS. transported, will vigorously polymerize,
have a tendency to form a surface film "Immediate use" means that the decompose, condense, or will become self-
under test; or hazardous chemical will be under the reactive under conditions of shocks,
(ii) Pensky-Martens Closed Tester (see control of and used only by the pressure or temperature.
American National Standard Method of person who transfers it from a "Use" means to package, handle, react,
Test for Flash Point by Pensky-Martens labeled container and only within the emit, extract, generate as a byproduct, or
Closed Tester, Z11.7-1979 (ASTM D 93- work shift in which it is transferred. transfer.
79)) for liquids with a viscosity equal to or "Importer" means the first business "Water-reactive" means a chemical that
greater than 45 SUS at 100 deg. F (37.8 with employees within the Customs reacts with water to release a gas that is
deg. C), or that contain suspended solids, Territory of the United States which either flammable or presents a health
or that have a tendency to form a surface receives hazardous chemicals hazard.
film under test; or produced in other countries for the "Work area" means a room or defined
(iii) Setaflash Closed Tester (see American purpose of supplying them to space in a workplace where hazardous
National Standard Method of Test for distributors or employers within the chemicals are produced or used, and where
Flash Point by Setaflash Closed Tester United States. employees are present. "Workplace"
(ASTM D 3278-78)). "Label" means any written, printed, means an establishment, job site, or
Organic peroxides, which undergo or graphic material displayed on or project, at one geographical location
autoaccelerating thermal decomposition, affixed to containers of hazardous containing one or more work areas.
1910.1200(d)

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Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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"Hazard determination." 1910.1200(d)(5) 31:9104
1910.1200(d)(1) The chemical manufacturer, importer section for labels and other forms of
Chemical manufacturers and importers or employer shall determine the warning, material safety data sheets, and
shall evaluate chemicals produced in their hazards of mixtures of chemicals as employee information and training will be
workplaces or imported by them to follows: met, and which also includes the
determine if they are hazardous. 1910.1200(d)(5)(i) following:
Employers are not required to evaluate If a mixture has been tested as a 1910.1200(e)(1)(i)
chemicals unless they choose not to rely whole to determine its hazards, the A list of the hazardous chemicals known
on the evaluation performed by the results of such to be present using an identity that is
chemical manufacturer or importer for the testing shall be used to determine referenced on the appropriate
chemical to satisfy this requirement. whether the mixture is hazardous; material safety data sheet (the list may be
1910.1200(d)(2) 1910.1200(d)(5)(ii) compiled for the workplace
Chemical manufacturers, importers or If a mixture has not been tested as a as a whole or for individual work areas);
employers evaluating chemicals shall whole to determine whether the and,
identify and consider the available mixture is a health hazard, the 1910.1200(e)(1)(ii)
scientific evidence concerning such mixture shall be assumed to present The methods the employer will use to
hazards. For health hazards, evidence the same health hazards as do the inform employees of the hazards of non-
which is statistically significant and which components which comprise one routine tasks (for example, the cleaning of
is based on at least one positive study percent (by weight or volume) or reactor vessels), and the hazards
conducted in accordance with established greater of the mixture, except that associated with chemicals contained in
scientific principles is considered to be the mixture shall be assumed to unlabeled pipes in their work areas.
sufficient to establish a hazardous effect if present a carcinogenic hazard if it 1910.1200(e)(2)
the results of the study meet the definitions contains a component in "Multi-employer workplaces."
of health hazards in this section. Appendix concentrations of 0.1 percent or Employers who produce, use, or store
A shall be consulted for the scope of greater which is considered to be a hazardous chemicals at a workplace in
health hazards covered, and Appendix B carcinogen under paragraph (d)(4) of such a way that the employees of other
shall be consulted for the criteria to be this section; employer(s) may be exposed (for example,
followed with respect to the completeness 1910.1200(d)(5)(iii) employees of a construction contractor
of the evaluation, and the data to be If a mixture has not been tested as a working on-site) shall additionally ensure
reported. whole to determine whether the that the hazard communication programs
1910.1200(d)(3) mixture is a physical hazard, the developed and implemented under this
The chemical manufacturer, importer or chemical manufacturer, importer, or paragraph (e) include the following:
employer evaluating chemicals shall treat employer may use whatever 1910.1200(e)(2)(i)
the following sources as establishing that scientifically valid data is available The methods the employer will use to
the chemicals listed in them are hazardous: to evaluate the physical hazard provide the other employer(s) on-site
1910.1200(d)(3)(i) potential of the mixture; and, access to material safety data sheets for
29 CFR part 1910, subpart Z, Toxic and 1910.1200(d)(5)(iv) each hazardous chemical the other
Hazardous Substances, Occupational If the chemical manufacturer, employer(s)' employees may be exposed
Safety and Health Administration importer, or employer has evidence to while working;
(OSHA); or, to indicate that a component present 1910.1200(e)(2)(ii)
1910.1200(d)(3)(ii) in the mixture in concentrations of The methods the employer will use to
"Threshold Limit Values for Chemical less than one percent (or in the case inform the other employer(s) of any
Substances and Physical Agents in the of carcinogens, less than 0.1 percent) precautionary measures that need to be
Work Environment," American could be released in concentrations taken to protect employees during the
Conference of Governmental Industrial which would exceed an established workplace's normal operating conditions
Hygienists (ACGIH) (latest edition). The OSHA permissible exposure limit or and in foreseeable emergencies; and,
chemical manufacturer, importer, or ACGIH Threshold Limit Value, or 1910.1200(e)(2)(iii)
employer is still responsible for evaluating could present a health risk to The methods the employer will use to
the hazards associated with the chemicals employees in those concentrations, inform the other employer(s) of the
in these source lists in accordance with the the mixture shall be assumed to labeling system used in the workplace.
requirements of this standard. present the same hazard. 1910.1200(e)(3)
1910.1200(d)(4) 1910.1200(d)(6) The employer may rely on an existing
Chemical manufacturers, importers and Chemical manufacturers, importers, hazard communication program to comply
employers evaluating chemicals shall treat or employers evaluating chemicals with these requirements, provided that it
the following sources as establishing that a shall describe in writing the meets the criteria established in this
chemical is a carcinogen or potential procedures they use to determine the paragraph (e).
carcinogen for hazard communication hazards of the chemical they 1910.1200(e)(4)
purposes: evaluate. The written procedures are The employer shall make the written
1910.1200(d)(4)(i) to be made available, upon request, hazard communication program available,
National Toxicology Program (NTP), to employees, their designated upon request, to employees, their
"Annual Report on Carcinogens" (latest representatives, the Assistant designated representatives, the Assistant
edition); Secretary and the Director. The Secretary and the Director, in accordance
1910.1200(d)(4)(ii) written description may be with the requirements of 29 CFR
International Agency for Research on incorporated into the written hazard 1910.1020 (e).
Cancer (IARC) "Monographs" (latest communication program required 1910.1200(e)(5)
editions); or under paragraph (e) of this section. Where employees must travel between
1910.1200(d)(4)(iii) 1910.1200(e) workplaces during a workshift, i.e., their
29 CFR part 1910, subpart Z, Toxic and Written hazard communication work is carried out at more than one
Hazardous Substances, Occupational program." geographical location, the written hazard
Safety and Health Administration. 1910.1200(e)(1) communication program may be kept at
Note: The "Registry of Toxic Effects of Employers shall develop, implement, the primary workplace facility.
Chemical Substances" published by the and maintain at each workplace, a 1910.1200(f)
National Institute for Occupational Safety written hazard communication "Labels and other forms of warning."
and Health indicates whether a chemical program which at least describes 1910.1200(f)(1)
has been found by NTP or IARC to be a how the criteria specified in The chemical manufacturer, importer, or
potential carcinogen. paragraphs (f), (g), and (h) of this distributor shall ensure that each container

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Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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of hazardous chemicals leaving the the hazard communication program, 31:9105
workplace is labeled, tagged or marked will provide employees with the chemical is shipped or introduced into the
with the following information: specific information regarding the workplace again.
1910.1200(f)(1)(i) physical and health hazards of the 1910.1200(g)
Identity of the hazardous chemical(s); hazardous chemical. "Material safety data sheets."
1910.1200(f)(1)(ii) 1910.1200(f)(6) 1910.1200(g)(1)
Appropriate hazard warnings; and The employer may use signs, Chemical manufacturers and importers
1910.1200(f)(1)(iii) placards, process sheets, batch shall obtain or develop a material safety
Name and address of the chemical tickets, operating procedures, or data sheet for each hazardous chemical
manufacturer, importer, or other other such written materials they produce or import. Employers shall
responsible party. in lieu of affixing labels to individual have a material safety data sheet in the
1910.1200(f)(2) stationary process containers, as long workplace for each hazardous chemical
1910.1200(f)(2)(i) as the alternative method identifies which they use.
For solid metal (such as a steel beam or a the containers to which it is 1910.1200(g)(2)
metal casting), solid wood, or plastic items applicable and conveys the Each material safety data sheet shall be in
that are not exempted as articles due to information required by paragraph English (although the employer may
their downstream use, or shipments of (f)(5) of this section to be on a label. maintain copies in other languages as
whole grain, the required label may be The written materials shall be readily well), and shall contain at least the
transmitted to the customer at the time of accessible to the employees in their following information:
the initial shipment, and need not be work area throughout each work 1910.1200(g)(2)(i)
included with subsequent shipments to the shift. The identity used on the label, and, except
same employer unless the information on 1910.1200(f)(7) as provided for in paragraph (i) of this
the label changes; The employer is not required to label section on trade secrets:
1910.1200(f)(2)(ii) portable containers into which 1910.1200(g)(2)(i)(A)
The label may be transmitted with the hazardous chemicals are transferred If the hazardous chemical is a single
initial shipment itself, or with the material from labeled containers, and which substance, its chemical and common
safety data sheet that is to be provided are intended only for the immediate name(s);
prior to or at the time of the first shipment; use of the employee who performs 1910.1200(g)(2)(i)(B)
and, the transfer. For purposes of this If the hazardous chemical is a mixture
1910.1200(f)(2)(iii) section, drugs which are dispensed which has been tested as a whole to
This exception to requiring labels on every by a pharmacy to a health care determine its hazards, the chemical and
container of hazardous chemicals is only provider for direct administration to common name(s) of the ingredients which
for the solid material itself, and does not a patient are exempted from labeling. contribute to these known hazards, and the
apply to hazardous chemicals used in 1910.1200(f)(8) common name(s) of the mixture itself; or,
conjunction with, or known to be present The employer shall not remove or 1910.1200(g)(2)(i)(C)
with, the material and to which employees deface existing labels on incoming If the hazardous chemical is a mixture
handling the items in transit may be containers of hazardous chemicals, which has not been tested as a whole:
exposed (for example, cutting fluids or unless the container is immediately 1910.1200(g)(2)(i)(C)(1)
pesticides in grains). marked with the required The chemical and common name(s) of all
1910.1200(f)(3) information. ingredients which have been determined to
Chemical manufacturers, importers, or 1910.1200(f)(9) be health hazards, and which comprise 1%
distributors shall ensure that each The employer shall ensure that labels or greater of the composition, except that
container of hazardous chemicals leaving or other forms of warning are chemicals identified as carcinogens under
the workplace is labeled, tagged, or legible, in English, and prominently paragraph (d) of this section shall be listed
marked in accordance with this section in displayed on the container, or readily if the concentrations are 0.1% or greater;
a manner which does not conflict with the available in the work area throughout and,
requirements of the Hazardous Materials each work shift. Employers having 1910.1200(g)(2)(i)(C)(2)
Transportation Act (49 U.S.C. 1801 et employees who speak other The chemical and common name(s) of all
seq.) and regulations issued under that Act languages may add the information ingredients which have been determined to
by the Department of Transportation. in their language to the material be health hazards, and which comprise less
1910.1200(f)(4) presented, as long as the information than 1% (0.1% for carcinogens) of the
If the hazardous chemical is regulated by is presented in English as well. mixture, if there is evidence that the
OSHA in a substance-specific health 1910.1200(f)(10) ingredient(s) could be released from the
standard, the chemical manufacturer, The chemical manufacturer, mixture in concentrations which would
importer, distributor or employer shall importer, distributor or employer exceed an established OSHA permissible
ensure that the labels or other forms of need not affix new labels to comply exposure limit or ACGIH Threshold Limit
warning used are in accordance with the with this section if existing labels Value, or could present a health risk to
requirements of that standard. already convey the required employees; and,
1910.1200(f)(5) information. 1910.1200(g)(2)(i)(C)(3)
Except as provided in paragraphs (f)(6) 1910.1200(f)(11) The chemical and common name(s) of all
and (f)(7) of this section, the employer Chemical manufacturers, importers, ingredients which have been determined to
shall ensure that each container of distributors, or employers who present a physical hazard when present in
hazardous chemicals in the workplace is become newly aware of any the mixture;
labeled, tagged or marked with the significant information regarding the 1910.1200(g)(2)(ii)
following information: hazards of a chemical shall revise the Physical and chemical characteristics of
1910.1200(f)(5)(i) labels for the chemical within three the hazardous chemical (such as vapor
Identity of the hazardous chemical(s) months of becoming aware of the pressure, flash point);
contained therein; and, new information. Labels on 1910.1200(g)(2)(iii)
1910.1200(f)(5)(ii) containers of hazardous chemicals The physical hazards of the hazardous
Appropriate hazard warnings, or shipped after that time shall contain chemical, including the potential for fire,
alternatively, words, pictures, symbols, or the new information. If the chemical explosion, and reactivity;
combination thereof, which provide at is not currently produced or 1910.1200(g)(2)(iv)
least general information regarding the imported, the chemical The health hazards of the hazardous
hazards of the chemicals, and which, in manufacturer, importers, distributor, chemical, including signs and symptoms
conjunction with the other information or employer shall add the of exposure, and any medical conditions
immediately available to employees under information to the label before the

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Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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which are generally recognized as being manufacturer, importer or employer 31:9106
aggravated by exposure to the chemical; preparing the material safety data of the over-the-counter purchase, and shall
1910.1200(g)(2)(v) sheet becomes newly aware of any post a sign or otherwise inform such
The primary route(s) of entry; significant information regarding the employers that a material safety data sheet
1910.1200(g)(2)(vi) hazards of a chemical, or ways to is available;
The OSHA permissible exposure limit, protect against the hazards, this new 1910.1200(g)(7)(v)
ACGIH Threshold Limit Value, and any information shall be added to the If an employer without a commercial
other exposure limit used or recommended material safety data sheet account purchases a hazardous chemical
by the chemical manufacturer, importer, or within three months. If the chemical from a retail distributor not
employer preparing the material safety is not currently being produced or required to have material safety data
data sheet, where available; imported the chemical manufacturer sheets on file (i.e., the retail distributor
1910.1200(g)(2)(vii) or importer shall add the information does not have commercial accounts and
Whether the hazardous chemical is listed to the material safety data sheet does not use the materials), the retail
in the National Toxicology Program before the chemical is introduced distributor shall provide the employer,
(NTP) Annual Report on Carcinogens into the workplace again. upon request, with the name, address, and
(latest edition) or has been found to be a 1910.1200(g)(6) telephone number of the
potential carcinogen in the International 1910.1200(g)(6)(i) chemical manufacturer, importer, or
Agency for Research on Cancer (IARC) Chemical manufacturers or importers distributor from which a material safety
Monographs (latest editions), or by shall ensure that distributors and data sheet can be obtained;
OSHA; employers are provided an 1910.1200(g)(7)(vi)
1910.1200(g)(2)(viii) appropriate material safety data sheet Wholesale distributors shall also provide
Any generally applicable precautions for with their initial shipment, and with material safety data sheets to employers or
safe handling and use which are known to the first shipment after a material other distributors upon request; and,
the chemical manufacturer, importer or safety data sheet is updated; 1910.1200(g)(7)(vii)
employer preparing the material safety 1910.1200(g)(6)(ii) Chemical manufacturers, importers, and
data sheet, including appropriate hygienic The chemical manufacturer or distributors need not provide material
practices, protective measures during importer shall either provide material safety data sheets to retail distributors
repair and maintenance of contaminated safety data sheets with the shipped that have informed them that the retail
equipment, and procedures for clean-up of containers or send them to the distributor does not sell the product to
spills and leaks; distributor or employer prior to or at commercial accounts or open the sealed
1910.1200(g)(2)(ix) the time of the shipment; container to use it in their own
Any generally applicable control measures 1910.1200(g)(6)(iii) workplaces.
which are known to the chemical If the material safety data sheet is not 1910.1200(g)(8)
manufacturer, importer or employer provided with a shipment that has The employer shall maintain in the
preparing the material safety data sheet, been labeled as a hazardous workplace copies of the required material
such as appropriate engineering controls, chemical, the distributor or employer safety data sheets for each hazardous
work practices, or personal protective shall obtain one from the chemical chemical, and shall ensure that they are
equipment; manufacturer or importer as soon as readily accessible during each work shift
1910.1200(g)(2)(x) possible; and, to employees when they are in their work
Emergency and first aid procedures; 1910.1200(g)(6)(iv) area(s). (Electronic access, microfiche, and
1910.1200(g)(2)(xi) The chemical manufacturer or other alternatives to maintaining paper
The date of preparation of the material importer shall also provide copies of the material safety data sheets
safety data sheet or the last change to it; distributors or employers with a are permitted as long as no barriers to
and, material safety data sheet upon immediate employee access in each
1910.1200(g)(2)(xii) request. workplace are created by such options.)
The name, address and telephone number 1910.1200(g)(7) 1910.1200(g)(9)
of the chemical manufacturer, importer, 1910.1200(g)(7)(i) Where employees must travel between
employer or other responsible party Distributors shall ensure that workplaces during a workshift, i.e., their
preparing or distributing the material material safety data sheets, and work is carried out at more than one
safety data sheet, who can provide updated information, are provided to geographical location, the material safety
additional information on the hazardous other distributors and employers with data sheets may be kept at the primary
chemical and appropriate emergency their initial shipment and with the workplace facility. In this situation, the
procedures, if necessary. first shipment after a material safety employer shall ensure that employees can
1910.1200(g)(3) data sheet is updated; immediately obtain the required
If no relevant information is found for any 1910.1200(g)(7)(ii) information in an emergency.
given category on the material safety data The distributor shall either provide 1910.1200(g)(10)
sheet, the chemical manufacturer, importer material safety data sheets with the Material safety data sheets may be kept in
or employer preparing the material safety shipped containers, or send them to any form, including operating procedures,
data sheet shall mark it to indicate that no the other distributor or employer and may be designed to cover groups of
applicable information was found. prior to or at the time of the hazardous chemicals in a work area where
1910.1200(g)(4) shipment; it may be more appropriate to address the
Where complex mixtures have similar 1910.1200(g)(7)(iii) hazards of a process rather than individual
hazards and contents (i.e. the chemical Retail distributors selling hazardous hazardous chemicals. However, the
ingredients are essentially the same, but chemicals to employers having a employer shall ensure that in all cases the
the specific composition varies from commercial account shall provide a required information is provided for each
mixture to mixture), the chemical material safety data sheet to such hazardous chemical, and is readily
manufacturer, importer or employer may employers upon request, and shall accessible during each work shift to
prepare one material safety data sheet to post a sign or otherwise inform them employees when they are in in their work
apply to all of these similar mixtures. that a material safety data sheet is area(s).
1910.1200(g)(5) available; 1910.1200(g)(11)
The chemical manufacturer, importer or 1910.1200(g)(7)(iv) Material safety data sheets shall also be
employer preparing the material safety Wholesale distributors selling made readily available, upon request, to
data sheet shall ensure that the information hazardous chemicals to employers designated representatives and to the
recorded accurately reflects the scientific over-the-counter may also provide Assistant Secretary, in accordance with the
evidence used in making the hazard material safety data sheets upon the requirements of 29 CFR 1910.1020(e).
determination. If the chemical request of the employer at the time The Director shall also be given access to

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Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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material safety data sheets in the same 1910.1200(i)(1)(ii) 31:9107
manner. Information contained in the material 1910.1200(i)(3)(ii)(E)
1910.1200(h) safety data sheet concerning the To select or assess appropriate personal
"Employee information and training." properties and effects of the protective equipment for exposed
1910.1200(h)(1) hazardous chemical is disclosed; employees;
Employers shall provide employees with 1910.1200(i)(1)(iii) 1910.1200(i)(3)(ii)(F)
effective information and training on The material safety data sheet To design or assess engineering controls
hazardous chemicals in their work area at indicates that the specific chemical or other protective measures for exposed
the time of their initial assignment, and identity is being withheld as a trade employees; and,
whenever a new physical or health hazard secret; and, 1910.1200(i)(3)(ii)(G)
the employees have not previously been 1910.1200(i)(1)(iv) To conduct studies to determine the health
trained about is introduced into their work The specific chemical identity is effects of exposure.
area. Information and training may be made available to health 1910.1200(i)(3)(iii)
designed to cover categories of hazards professionals, employees, and The request explains in detail why the
(e.g., flammability, carcinogenicity) or designated representatives in disclosure of the specific chemical
specific chemicals. Chemical-specific accordance with the applicable identity is essential and that, in lieu
information must always be available provisions of this paragraph. thereof, the disclosure of the following
through labels and material safety data 1910.1200(i)(2) information to the health professional,
sheets. Where a treating physician or nurse employee, or designated representative,
1910.1200(h)(2) determines that a medical emergency would not satisfy the purposes described
"Information." Employees shall be exists and the specific chemical in paragraph (i)(3)(ii) of this section:
informed of: identity of a hazardous chemical is 1910.1200(i)(3)(iii)(A)
1910.1200(h)(2)(i) necessary for emergency or first-aid The properties and effects of the chemical;
The requirements of this section; treatment, the chemical 1910.1200(i)(3)(iii)(B)
1910.1200(h)(2)(ii) manufacturer, importer, or employer Measures for controlling workers'
Any operations in their work area where shall immediately disclose the exposure to the chemical;
hazardous chemicals are present; and, specific chemical identity of a trade 1910.1200(i)(3)(iii)(C)
1910.1200(h)(2)(iii) secret chemical to that treating Methods of monitoring and analyzing
The location and availability of the written physician or nurse, regardless of the worker exposure to the chemical; and,
hazard communication program, including existence of a written statement of 1910.1200(i)(3)(iii)(D)
the required list(s) of hazardous chemicals, need or a confidentiality agreement. Methods of diagnosing and treating
and material safety data sheets required by The chemical manufacturer, harmful exposures to the chemical;
this section. importer, or employer may require a 1910.1200(i)(3)(iv)
1910.1200(h)(3) written statement of need and The request includes a description of the
"Training." Employee training shall confidentiality agreement, in procedures to be used to maintain the
include at least: accordance with the provisions of confidentiality of the disclosed
1910.1200(h)(3)(i) paragraphs (i)(3) and (4) of this information; and,
Methods and observations that may be section, as soon as circumstances 1910.1200(i)(3)(v)
used to detect the presence or release of a permit. The health professional, and the employer
hazardous chemical in the work area (such 1910.1200(i)(3) or contractor of the services of the health
as monitoring conducted by the employer, In non-emergency situations, a professional (i.e. downstream employer,
continuous monitoring devices, visual chemical manufacturer, importer, or labor organization, or individual
appearance or odor of hazardous employer shall, upon request, employee), employee, or designated
chemicals when being released, etc.); disclose a specific chemical identity, representative, agree in a written
1910.1200(h)(3)(ii) otherwise permitted to be withheld confidentiality agreement that the health
The physical and health hazards of the under paragraph (i)(1) of this section, professional, employee, or designated
chemicals in the work area; to a health professional (i.e. representative, will not use the trade secret
1910.1200(h)(3)(iii) physician, industrial hygienist, information for any purpose other than the
The measures employees can take to toxicologist, epidemiologist, or health need(s) asserted and agree not to
protect themselves from these hazards, occupational health nurse) providing release the information under any
including specific procedures the medical or other occupational health circumstances other than to OSHA, as
employer has implemented to protect services to exposed employee(s), and provided in paragraph (i)(6) of this
employees from exposure to hazardous to employees or designated section, except as authorized by the terms
chemicals, such as appropriate work representatives, if: of the agreement or by the chemical
practices, emergency procedures, and 1910.1200(i)(3)(i) manufacturer, importer, or employer.
personal protective equipment to be used; The request is in writing; 1910.1200(i)(4)
and, 1910.1200(i)(3)(ii) The confidentiality agreement authorized
1910.1200(h)(3)(iv) The request describes with by paragraph (i)(3)(iv) of this section:
The details of the hazard communication reasonable detail one or more of the 1910.1200(i)(4)(i)
program developed by the employer, following occupational health needs May restrict the use of the information to
including an explanation of the labeling for the information: the health purposes indicated in the written
system and the material safety data sheet, 1910.1200(i)(3)(ii)(A) statement of need;
and how employees can obtain and use the To assess the hazards of the 1910.1200(i)(4)(ii)
appropriate hazard information. chemicals to which employees will May provide for appropriate legal
1910.1200(i) be exposed; remedies in the event of a breach of the
"Trade secrets." 1910.1200(i)(3)(ii)(B) agreement, including stipulation of a
1910.1200(i)(1) To conduct or assess sampling of the reasonable pre-estimate of likely damages;
The chemical manufacturer, importer, or workplace atmosphere to determine and,
employer may withhold the specific employee exposure levels; 1910.1200(i)(4)(iii)
chemical identity, including the chemical 1910.1200(i)(3)(ii)(C) May not include requirements for the
name and other specific identification of a To conduct pre-assignment or posting of a penalty bond.
hazardous chemical, from the material periodic medical surveillance of 1910.1200(i)(5)
safety data sheet, provided that: exposed employees; Nothing in this standard is meant to
1910.1200(i)(1)(i) 1910.1200(i)(3)(ii)(D) preclude the parties from pursuing non-
The claim that the information withheld is To provide medical treatment to contractual remedies to the extent
a trade secret can be supported; exposed employees; permitted by law.

52 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)

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1910.1200(i)(6) confidentiality of the information, 31:9108
If the health professional, employee, or the chemical manufacturer, importer, paragraph (b)(6)(iv) only applies to wood
designated representative receiving the or employer will be subject to and wood products including lumber
trade secret information decides that there citation by OSHA. which will not be processed, where the
is a need to disclose it to OSHA, the 1910.1200(i)(10)(ii) manufacturer or importer can establish that
chemical manufacturer, importer, or If a chemical manufacturer, importer, the only hazard they pose to employees is
employer who provided the information or employer demonstrates to OSHA the potential for flammability or
shall be informed by the health that the execution of a confidentiality combustibility, and that the exemption
professional, employee, or designated agreement would not provide does not apply to wood or wood products
representative prior to, or at the same time sufficient protection against the which have been treated with a hazardous
as, such disclosure. potential harm from the unauthorized chemical covered by this standard, and
1910.1200(i)(7) disclosure of a trade secret specific wood which may be subsequently sawed
If the chemical manufacturer, importer, or chemical identity, the or cut generating dust has been stayed
employer denies a written request for Assistant Secretary may issue such from March 11, 1994 to August 11, 1994.
disclosure of a specific chemical identity, orders or impose such additional [59 FR 17479, April 13, 1994; 59 FR
the denial must: limitations or conditions upon the 65947, Dec. 22, 1994; 61 FR 5507, Feb.
1910.1200(i)(7)(i) disclosure of the requested chemical 13, 1996]
Be provided to the health professional, information as may be appropriate to
employee, or designated representative, assure that the occupational health Health Hazard Definitions (Mandatory)
within thirty days of the request; services are provided without an - 1910.1200 Appendix A
1910.1200(i)(7)(ii) undue risk of harm to the chemical Although safety hazards related to the
Be in writing; manufacturer, importer, or employer. physical characteristics of a chemical can
1910.1200(i)(7)(iii) 1910.1200(i)(11) be objectively defined in terms of testing
Include evidence to support the claim that If a citation for a failure to release requirements (e.g. flammability), health
the specific chemical identity is a trade specific chemical identity hazard definitions are less precise and
secret; information is contested by the more subjective. Health hazards may
1910.1200(i)(7)(iv) chemical manufacturer, importer, or cause measurable changes in the body -
State the specific reasons why the request employer, the matter will be such as decreased pulmonary function.
is being denied; and, adjudicated before the Occupational These changes are generally indicated by
1910.1200(i)(7)(v) Safety and Health Review the occurrence of signs and symptoms in
Explain in detail how alternative Commission in accordance with the the exposed employees - such as shortness
information may satisfy the specific Act's enforcement scheme and the of breath, a non-measurable, subjective
medical or occupational health need applicable Commission rules of feeling. Employees exposed to such
without revealing the specific chemical procedure. In accordance with the hazards must be apprised of both the
identity. Commission rules, when a chemical change in body function and the signs and
1910.1200(i)(8) manufacturer, importer, or employer symptoms that may occur to signal that
The health professional, employee, or continues to withhold the change.
designated representative whose request information during the contest, the The determination of occupational health
for information is denied under paragraph Administrative Law Judge may hazards is complicated by the fact that
(i)(3) of this section may refer the request review the citation and supporting many of the effects or signs and symptoms
and the written denial of the request to documentation "in camera" or issue occur commonly in non-occupationally
OSHA for consideration. appropriate orders to protect the exposed populations, so that effects of
1910.1200(i)(9) confidentiality of such matters. exposure are difficult to separate from
When a health professional, employee, or 1910.1200(i)(12) normally occurring illnesses.
designated representative refers the denial Notwithstanding the existence of a Occasionally, a substance causes an effect
to OSHA under paragraph (i)(8) of this trade secret claim, a chemical that is rarely seen in the population at
section, OSHA shall consider the evidence manufacturer, importer, or employer large, such as angiosarcomas caused by
to determine if: shall, upon request, disclose to the vinyl chloride exposure, thus making it
1910.1200(i)(9)(i) Assistant Secretary any information easier to ascertain that the occupational
The chemical manufacturer, importer, or which this section requires the exposure was the primary causative factor.
employer has supported the claim that the chemical manufacturer, importer, or More often, however, the effects are
specific chemical identity is a trade secret; employer to make available. Where common, such as lung cancer. The
1910.1200(i)(9)(ii) there is a trade secret claim, such situation is further complicated by the fact
The health professional, employee, or claim shall be made no later than at that most chemicals have not been
designated representative has supported the time the information is provided adequately tested to determine their health
the claim that there is a medical or to the Assistant Secretary so that hazard potential, and data do not exist to
occupational health need for the suitable determinations of trade substantiate these effects.
information; and, secret status can be made and the There have been many attempts to
1910.1200(i)(9)(iii) necessary protections can be categorize effects and to define them in
The health professional, employee or implemented. various ways. Generally, the terms "acute"
designated representative has 1910.1200(i)(13) and "chronic" are used to delineate
demonstrated adequate means to protect Nothing in this paragraph shall be between effects on the basis of severity or
the confidentiality. construed as requiring the disclosure duration. "Acute" effects usually occur
1910.1200(i)(10) under any circumstances of process rapidly as a result of short-term exposures,
1910.1200(i)(10)(i) or percentage of mixture information and are of short duration. "Chronic"
If OSHA determines that the specific which is a trade secret. effects generally occur as a result of long-
chemical identity requested under 1910.1200(j) term exposure, and are of long duration.
paragraph (i)(3) of this section is not a "Effective dates." Chemical The acute effects referred to most
"bona fide" trade secret, or that it is a trade manufacturers, importers, frequently are those defined by the
secret, but the requesting health distributors, and employers shall be American National Standards Institute
professional, employee, or designated in compliance with all provisions of (ANSI) standard for Precautionary
representative has a legitimate medical or this section by March 11, 1994. Labeling of Hazardous Industrial
occupational health need for the Note: The effective date of the Chemicals (Z129.1-1988) - irritation,
information, has executed a written clarification that the exemption of corrosivity, sensitization and lethal dose.
confidentiality agreement, and has shown wood and wood products from the Although these are important health
adequate means to protect the Hazard Communication standard in effects, they do not adequately cover the

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 53


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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considerable range of acute effects which vapor, or 2 milligrams per liter or 31:9109
may occur as a result of occupational less of mist, fume, or dust, when a. Hepatotoxins: Chemicals which produce
exposure, such as, for example, narcosis. administered by continuous liver damage
Similarly, the term chronic effect is often inhalation for one hour (or less if Signs & Symptoms: Jaundice; liver
used to cover only death occurs within one hour) to enlargement
carcinogenicity, teratogenicity, and albino rats weighing between 200 Chemicals: Carbon tetrachloride;
mutagenicity. These effects are obviously and 300 grams each. nitrosamines
a concern in the workplace, but again, do 4. "Irritant:" A chemical, which is b. Nephrotoxins: Chemicals which
not adequately cover the area of chronic not corrosive, but which causes a produce kidney damage
effects, excluding, for example, blood reversibleinflammatory effect on Signs & Symptoms: Edema; proteinuria
dyscrasias (such as anemia), chronic living tissue by chemical action at Chemicals: Halogenated hydrocarbons;
bronchitis and liver atrophy. the site of contact. A chemical is a uranium
The goal of defining precisely, in skin irritant if, when tested on the c. Neurotoxins: Chemicals which produce
measurable terms, every possible health intact skin of albino rabbits by the their primary toxic effects on the nervous
effect that may occur in the workplace as a methods of 16 CFR 1500.41 for four system.
result of chemical exposures cannot hours exposure or by other Signs & Symptoms: Narcosis; behavioral
realistically be accomplished. This does appropriate techniques, it results in changes; decrease in motor
not negate the need for employees to be an empirical score of five or more. A functions
informed of such effects and protected chemical is an eye irritant if so Chemicals: Mercury; carbon disulfide
from them. Appendix B, which is also determined under the procedure d. Agents which act on the blood or
mandatory, outlines the principles and listed in 16 CFR 1500.42 or other hemato-poietic system: Decrease
procedures of hazard assessment. appropriate techniques. hemoglobin function; deprive the body
For purposes of this section, any chemicals 5. "Sensitizer:" A chemical that tissues of oxygen
which meet any of the following causes a substantial proportion of Signs & Symptoms: Cyanosis; loss of
definitions, as determined by the criteria exposed people or animals to consciousness
set forth in Appendix B are health hazards. develop an allergic reaction in Chemicals: Carbon monoxide; cyanides
However, this is not intended to be an normal tissue after repeated exposure e. Agents which damage the lung:
exclusive categorization scheme. If there to the chemical. Chemicals which irritate or damage
are available scientific data that involve 6. "Toxic." A chemical falling pulmonary tissue
other animal species or test methods, they within any of the following Signs & Symptoms: Cough; tightness in
must also be evaluated to determine the categories: chest; shortness of breath
applicability of the HCS. (a) A chemical that has a median Chemicals: Silica; asbestos
1. "Carcinogen:" A chemical is lethal dose (LD(50)) of more than 50 f. Reproductive toxins: Chemicals which
considered to be a carcinogen if: milligrams per kilogram but not affect the reproductive
(a) It has been evaluated by the more than 500 milligrams per capabilities including chromosomal
International Agency for Research on kilogram of body weight when damage (mutations) and effects
Cancer (IARC), and found to be a administered orally to albino rats on fetuses (teratogenesis)
carcinogen or potential carcinogen; or weighing between 200 and 300 Signs & Symptoms: Birth defects;
(b) It is listed as a carcinogen or potential grams each. sterility
carcinogen in the Annual Report on (b) A chemical that has a median Chemicals: Lead; DBCP
Carcinogens published by the National lethal dose (LD(50)) of more than g. Cutaneous hazards: Chemicals which
Toxicology Program (NTP) (latest 200 milligrams per kilogram but not affect the dermal layer of the body
edition); or, c) It is regulated by OSHA as more than 1,000 milligrams per Signs & Symptoms: Defatting of the
a carcinogen. kilogram of body weight when skin; rashes; irritation
2. "Corrosive:" A chemical that causes administered by continuous contact Chemicals: Ketones; chlorinated
visible destruction of, or irreversible for 24 hours (or less if death occurs compounds
alterations in, living tissue by chemical within 24 hours) with the bare skin h. Eye hazards: Chemicals which affect
action at the site of contact. For example, a of albino rabbits weighing between the eye or visual capacity
chemical is considered to be corrosive if, two and three kilograms each. Signs & Symptoms: Conjunctivitis;
when tested on the intact skin of albino (c) A chemical that has a median corneal damage
rabbits by the method described by the lethal concentration (LC(50)) in air Chemicals: Organic solvents; acids
U.S. Department of Transportation in of more than 200 parts per million Hazard determination (Mandatory) -
appendix A to 49 CFR part 173, it destroys but not more than 2,000 parts per 1910.1200 Appendix B
or changes irreversibly the structure of the million by volume of gas or vapor, or The quality of a hazard communication
tissue at the site of contact following an more than two milligrams per liter program is largely dependent upon the
exposure period of four hours. This term but not more than 20 milligrams per adequacy and accuracy of the hazard
shall not refer to action on inanimate liter of mist, fume, or dust, when determination. The hazard determination
surfaces. administered by continuous requirement of this standard is
3. "Highly toxic:" A chemical falling inhalation for one hour (or less if performance-oriented. Chemical
within any of the following categories: death occurs within one hour) to manufacturers, importers, and employers
(a) A chemical that has a median lethal albino rats weighing between 200 evaluating chemicals are not required to
dose (LD(50)) of 50 milligrams or less per and 300 grams each. follow any specific methods for
kilogram of body weight when 7. "Target organ effects." determining hazards, but they must be able
administered orally to albino rats weighing The following is a target organ to demonstrate that they have adequately
between 200 and 300 grams each. categorization of effects which may ascertained the hazards of the chemicals
(b) A chemical that has a median lethal occur, including examples of signs produced or imported in accordance with
dose (LD(50)) of 200 milligrams or less and symptoms and chemicals which the criteria set forth in this Appendix.
per kilogram of body weight when have been found to cause such Hazard evaluation is a process which
administered by continuous contact for 24 effects. These examples are relies heavily on the professional
hours (or less if death occurs within 24 presented to illustrate the range and judgment of the evaluator, particularly in
hours) with the bare skin of albino rabbits diversity of effects and hazards the area of chronic hazards. The
weighing between two and three kilograms found in the workplace, and the performance-orientation of the hazard
each. broad scope employers must determination does not diminish the duty
(c) A chemical that has a median lethal consider in this area, but are not of the chemical manufacturer, importer or
concentration (LC(50)) in air of 200 parts intended to be all-inclusive. employer to conduct a thorough
per million by volume or less of gas or evaluation, examining all relevant data and

54 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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producing a scientifically defensible that it is not simply information as to 31:9110
evaluation. For purposes of this standard, single or ephemeral events in the prior art or one which is merely a
the following criteria shall be used in conduct of the business, as, for mechanical improvement that a good
making hazard determinations that meet example, the amount or other terms mechanic can make. Novelty and
the requirements of this standard. of a secret bid for a contract or the invention are not requisite for a trade
1. "Carcinogenicity:" As described in salary of certain employees, or the secret as they are for patentability. These
paragraph (d)(4) of this section and security investments made or requirements are essential to patentability
Appendix A of this section, a contemplated, or the date fixed for because a patent protects against
determination by the National Toxicology the announcement of a new policy or unlicensed use of the patented device or
Program, the International Agency for for bringing out a new model or the process even by one who discovers it
Research on Cancer, or OSHA that a like. A trade secret is a process or properly through independent research.
chemical is a carcinogen or potential device for continuous use in the The patent monopoly is a reward to the
carcinogen will be considered conclusive operations of the business. Generally inventor. But such is not the case
evidence for purposes of this section. In it relates to the production of goods, with a trade secret. Its protection is not
addition, however, all available scientific as, for example, a machine or based on a policy of rewarding or
data on carcinogenicity must be evaluated formula for the production of an otherwise encouraging the development of
in accordance with the provisions of this article. It may, however, relate to the secret processes or devices. The protection
Appendix and the requirements of the rule. sale of goods or to other operations is merely against breach of faith and
2. "Human data:" Where available, in the business, such as a code for reprehensible means of learning another's
epidemiological studies and case reports of determining discounts, rebates or secret. For this limited protection it is not
adverse health effects shall be considered other concessions in a price list or appropriate to require also the kind of
in the evaluation. catalogue, or a list of specialized novelty and invention which is a requisite
3. "Animal data:" Human evidence of customers, or a method of of patentability. The nature of the secret is,
health effects in exposed populations is bookkeeping or other office however, an important factor in
generally not available for the majority of management. determining the kind of relief that is
chemicals produced or used in the "Secrecy." The subject matter of a appropriate against one who is subject to
workplace. Therefore, the available results trade secret must be secret. Matters liability under the rule stated in this
of toxicological testing in animal of public knowledge or of general Section. Thus, if the secret consists of a
populations shall be used to predict the knowledge in an industry cannot be device or process which is a novel
health effects that may be experienced by appropriated by one as his secret. invention, one who acquires the secret
exposed workers. In particular, the Matters which are completely wrongfully is ordinarily enjoined from
definitions of certain acute hazards refer to disclosed by the goods which one further use of it and is required to account
specific animal testing results (see markets cannot be his secret. for the profits derived from his past use. If,
Appendix A). Substantially, a trade secret is known on the other hand, the secret consists of
4. "Adequacy and reporting of data." only in the particular business in mechanical improvements that a good
The results of any studies which are which it is used. It is not requisite mechanic can make without resort to the
designed and conducted according to that only the proprietor of the secret, the wrongdoer's liability may be
established scientific principles, and which business know it. He may, without limited to damages, and an injunction
report statistically significant conclusions losing his protection, communicate it against future use of the improvements
regarding the health effects of a chemical, to employees involved in its use. He made with the aid of the secret may be
shall be a sufficient basis for a hazard may likewise communicate it to inappropriate.
determination and reported on any others pledged to secrecy. Others Guidelines for Employer Compliance
material safety data sheet. In vitro studies may also know of it independently, (Advisory) - 1910.1200 Appendix E
alone generally do not form the basis for a as, for example, when they have The Hazard Communication Standard
definitive finding of hazard under the HCS discovered the process or formula by (HCS) is based on a simple concept - that
since they have a positive or negative independent invention and are employees have both a need and a right to
result rather than a statistically significant keeping it secret. Nevertheless, a know the hazards and identities of the
finding. substantial element of secrecy must chemicals they are exposed to when
The chemical manufacturer, importer, or exist, so that, except by the use of working. They also need to know what
employer may also report the results of improper means, there would be protective measures are available to
other scientifically valid studies which difficulty in acquiring the prevent adverse effects from occurring.
tend to refute the findings of hazard. information. An exact definition of a The HCS is designed to provide
Information sources (Advisory) – trade secret is not possible. Some employees with the information they need.
1910.1200 Appendix C factors to be considered in Knowledge acquired under the HCS will
Editorial Note: The Federal Register of determining whether given help employers provide safer workplaces
March 7, 1996, removed 1910.1200 information is one's trade secret are: for their employees. When employers have
Appendix C.[61 FR 9227, March 7, 1996] (1) The extent to which the information about the chemicals being
Definition of "Trade Secret" information is known outside of his used, they can take steps to reduce
(Mandatory) - 1910.1200 Appendix D business; (2) the extent to which it is exposures, substitute less hazardous
The following is a reprint of the known by employees and others materials, and establish proper work
"Restatement of Torts" section 757, involved in his business; (3) the practices. These efforts will help prevent
comment b (1939): extent of measures taken by him to the occurrence of work-related illnesses
b. "Definition of trade secret." A trade guard the secrecy of the information; and injuries caused by chemicals.
secret may consist of any formula, pattern, (4) the value of the information to The HCS addresses the issues of
device or compilation of information him and his competitors; (5) the evaluating and communicating hazards to
which is used in one's business, and which amount of effort or money expended workers. Evaluation of chemical hazards
gives him an opportunity to obtain an by him in developing the involves a number of technical concepts,
advantage over competitors who do not information; (6) the ease or difficulty and is a process that requires the
know or use it. It may be a formula for a with which the information could be professional judgment of experienced
chemical compound, a process of properly acquired or duplicated by experts. That's why the HCS is designed
manufacturing, treating or preserving others. so that employers who simply use
materials, a pattern for a machine or other "Novelty and prior art." A trade chemicals, rather than produce or import
device, or a list of customers. It differs secret may be a device or process them, are not required to evaluate the
from other secret information in a business which is patentable; but it need not hazards of those chemicals. Hazard
(see s759 of the Restatement of Torts be that. It may be a device or process determination is the responsibility of the
which is not included in this Appendix) in which is clearly anticipated in the producers and importers of the materials.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 55


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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Producers and importers of chemicals are employers to which they ship the 31:9111
then required to provide the hazard chemicals. The information is to be employees would be protected under the
information to employers that purchase provided automatically. Every limited sealed container provisions. In this
their products. container of hazardous chemicals situation, requirements for obtaining and
Employers that don't produce or import you receive must be labeled, tagged, maintaining MSDSs are limited to
chemicals need only focus on those parts or marked with the required providing access to those received with
of the rule that deal with establishing a information. Your suppliers must containers while the substance is in the
workplace program and communicating also send you a properly completed workplace, and requesting MSDSs when
information to their workers. This material safety data sheet (MSDS) at employees request access for those not
appendix is a general guide for such the time of the first shipment of the received with the containers. However, as
employers to help them determine what's chemical, and with the next shipment a distributor of hazardous chemicals, that
required under the rule. It does not after the MSDS is updated with new employer will still have responsibilities for
supplant or substitute for the regulatory and significant information about the providing MSDSs
provisions, but rather provides a simplified hazards. to downstream customers at the time of the
outline of the steps an average employer You can rely on the information first shipment and when the MSDS is
would follow to meet those requirements. received from your suppliers. You updated. Therefore, although they may not
1. "Becoming Familiar With The Rule." have no independent duty to analyze be required for the employees in the work
OSHA has provided a simple summary of the chemical or evaluate the hazards operation, the distributor may,
the HCS in a pamphlet entitled "Chemical of it. Employers that "use" nevertheless, have to have MSDSs to
Hazard Communication," OSHA hazardous chemicals must have a satisfy other requirements of the rule.
Publication Number 3084. Some program to ensure the information is 2. "Identify Responsible Staff"
employers prefer to begin to become provided to exposed employees. Hazard communication is going to be a
familiar with the rule's requirements by "Use" means to package, handle, continuing program in your facility.
reading this pamphlet. A copy may be react, or transfer. This is an Compliance with the HCS is not a "one
obtained from your local OSHA Area intentionally broad scope, and shot deal." In order to have a successful
Office, or by contacting the OSHA includes any situation where a program, it will be necessary to assign
Publications Office at (202) 523-9667. chemical is present in such a way responsibility for both the initial and
The standard is long, and some parts of it that employees may be exposed ongoing activities that have to be
are technical, but the basic concepts are under normal conditions of use or in undertaken to comply with the rule. In
simple. In fact, the requirements reflect a foreseeable emergency. some cases, these activities may already be
what many employers have been doing for The requirements of the rule that part of current job assignments. For
years. You may find that you are already deal specifically with the hazard example, site supervisors are frequently
largely in compliance with many of the communication program are found in responsible for on-the-job training
provisions, and will simply have to modify this section in paragraphs (e), written sessions. Early identification of the
your existing programs somewhat. If you hazard communication program; (f), responsible employees, and involvement
are operating in an OSHA-approved State labels and other forms of warning; of them in the development of your plan of
Plan State, you must comply with the (g), material safety data sheets; and action, will result in a more effective
State's requirements, which may be (h), employee information and program design. Evaluation of the
different than those of the Federal rule. training. The requirements of these effectiveness of your program will also be
Many of the State Plan States had hazard paragraphs should be the focus of enhanced by involvement of affected
communication or "right-to-know" laws your attention. Concentrate on employees.
prior to promulgation of the Federal rule. becoming familiar with them, using For any safety and health program, success
Employers in State Plan States should paragraphs (b), scope and depends on commitment at every level of
contact their State OSHA offices for more application, and (c), definitions, as the organization. This is particularly true
information regarding applicable references when needed to help for hazard communication, where success
requirements. explain the provisions. requires a change in behavior. This will
The HCS requires information to be There are two types of work only occur if employers understand the
prepared and transmitted regarding all operations where the coverage of the program, and are committed to its
hazardous chemicals. The HCS rule is limited. These are laboratories success, and if employees are motivated
covers both physical hazards (such as and operations where chemicals are by the people presenting the information
flammability), and health hazards (such as only handled in sealed containers to them.
irritation, lung damage, and cancer). Most (e.g., a warehouse). The limited 3. "Identify Hazardous Chemicals in the
chemicals used in the workplace have provisions for these workplaces can Workplace."
some hazard potential, and thus will be be found in paragraph (b) of this The standard requires a list of hazardous
covered by the rule. section, scope and application. chemicals in the workplace as part of the
One difference between this rule and many Basically, employers having these written hazard communication program.
others adopted by OSHA is that this one is types of work operations need only The list will eventually serve as an
performance-oriented. That means that keep labels on containers as they are inventory of everything for which an
you have the flexibility to adapt the rule to received; maintain material safety MSDS must be maintained. At this point,
the needs of your workplace, rather than data sheets that are received, and however, preparing the list will help you
having to follow specific, rigid give employees access to them; and complete the rest of the program since it
requirements. It also means that you have provide information and training for will give you some idea of the scope of the
to exercise more judgment to implement employees. Employers do not have program required for compliance in your
an appropriate and effective program. to have written hazard facility.
The standard's design is simple. Chemical communication programs and lists of The best way to prepare a comprehensive
manufacturers and importers must chemicals for these types of list is to survey the workplace. Purchasing
evaluate the hazards of the chemicals they operations. records may also help, and certainly
produce or import. Using that information, The limited coverage of laboratories employers should establish procedures to
they must then prepare labels for and sealed container operations ensure that in the future purchasing
containers, and more detailed technical addresses the obligation of an procedures result in MSDSs being
bulletins called material safety data sheets employer to the workers in the received before a material is used in the
(MSDS). operations involved, and does not workplace.
Chemical manufacturers, importers, and affect the employer's duties as a The broadest possible perspective should
distributors of hazardous chemicals are all distributor of chemicals. For be taken when doing the survey.
required to provide the appropriate labels example, a distributor may have Sometimes people think of "chemicals" as
and material safety data sheets to the warehouse operations where being only liquids in containers. The HCS

56 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


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covers chemicals in all physical forms - work operations which do not have 31:9112
liquids, solids, gases, vapors, fumes, and to comply with the written plan transferred by the employer from a labeled
mists - whether they are "contained" or requirements are laboratories and container to another container, the
not. The hazardous nature of the chemical work operations where employees employer will have to label that container
and the potential for exposure are the only handle chemicals in sealed unless it is subject to the portable
factors which determine whether a containers. See paragraph (b) of this container exemption. See paragraph (f) of
chemical is covered. If it's not hazardous, section, scope and application, for this section for specific labeling
it's not covered. If there is no potential for the specific requirements for these requirements. The primary information to
exposure (e.g., the chemical is inextricably two types of workplaces. be obtained from an OSHA-required label
bound and cannot be released), the rule The plan does not have to be lengthy is an identity for the material, and
does not cover the chemical. or complicated. It is intended to be a appropriate hazard warnings. The identity
Look around. Identify chemicals in blueprint for implementation of your is any term which appears on the label, the
containers, including pipes, but also think program - an assurance that all MSDS, and the list of chemicals, and thus
about chemicals generated in the work aspects of the requirements have links these three sources of information.
operations. For example, welding fumes, been addressed. The identity used by the supplier may be a
dusts, and exhaust fumes are all sources of Many trade associations and other common or trade name ("Black Magic
chemical exposures. Read labels provided professional groups have provided Formula"), or a chemical name (1,1,1,-
by suppliers for hazard information. Make sample programs and other trichloroethane). The hazard warning is a
a list of all chemicals in the workplace that assistance materials to affected brief statement of the hazardous effects of
are potentially hazardous. For your own employers. These have been very the chemical ("flammable," "causes lung
information and planning, you may also helpful to many employers since damage"). Labels frequently contain other
want to note on the list the location(s) of they tend to be tailored to the information, such as precautionary
the products within the workplace, and an particular industry involved. You measures ("do not use near open flame"),
indication of the hazards as found on the may wish to investigate whether but this information is provided
label. This will help you as you prepare your industry trade groups have voluntarily and is not required by the rule.
the rest of your program. developed such materials. Labels must be legible, and prominently
Paragraph (b) of this section, scope and Although such general guidance may displayed. There are no specific
application, includes exemptions for be helpful, you must remember that requirements for size or color, or any
various chemicals or workplace situations. the written program has to reflect specified text.
After compiling the complete list of what you are doing in your With these requirements in mind, the
chemicals, you should review paragraph workplace. Therefore, if you use a compliance officer will be looking for the
(b) of this section to determine if any of generic program it must be adapted following types of information to ensure
the items can be eliminated from the list to address the facility it covers. For that labeling will be properly implemented
because they are exempted materials. For example, the written plan must list in your facility:
example, food, drugs, and cosmetics the chemicals present at the site, 1. Designation of person(s) responsible for
brought into the workplace for employee indicate who is to be responsible for ensuring labeling of in-plant containers;
consumption are the various aspects of the program in 2. Designation of person(s) responsible for
exempt. So rubbing alcohol in the first aid your facility, and indicate where ensuring labeling of any shipped
kit would not be covered. written materials will be made containers;
Once you have compiled as complete a list available to employees. 3. Description of labeling system(s) used;
as possible of the potentially hazardous If OSHA inspects your workplace 4. Description of written alternatives to
chemicals in the workplace, the next step for compliance with the HCS, the labeling of in-plant containers (if used);
is to determine if you have received OSHA compliance officer will ask to and,
material safety data sheets for all of them. see your written plan at the outset of 5. Procedures to review and update label
Check your files against the inventory you the inspection. In general, the information when necessary.
have just compiled. If any are missing, following items will be considered in Employers that are purchasing and using
contact your supplier and request one. It is evaluating your program. hazardous chemicals - rather than
a good idea to document these requests, The written program must describe producing or distributing them - will
either by copy of a letter or a note how the requirements for labels and primarily be concerned with ensuring that
regarding telephone conversations. If you other forms of warning, material every purchased container is labeled. If
have MSDSs for chemicals that are not on safety data sheets, and employee materials are transferred into other
your list, figure out why. Maybe you don't information and training, are going containers, the employer must ensure that
use the chemical anymore. Or maybe you to be met in your facility. The these are labeled as well, unless they fall
missed it in your survey. Some suppliers following discussion provides the under the portable container exemption
do provide MSDSs for products that are type of information compliance (paragraph (f)(7) of this section). In terms
not hazardous. These do not have to be officers will be looking for to decide of labeling systems, you can simply
maintained by you. whether these elements of the hazard choose to use the labels provided by your
You should not allow employees to use communication program have been suppliers on the containers. These will
any chemicals for which you have not properly addressed: generally be verbal text labels, and do not
received an MSDS. The MSDS provides A. "Labels and Other Forms of usually include numerical rating systems
information you need to ensure proper Warning" or symbols that require special training.
protective measures are implemented prior In-plant containers of hazardous The most important thing to remember is
to exposure. chemicals must be labeled, tagged, that this is a continuing duty - all in-plant
4. "Preparing and Implementing a or marked with the identity of the containers of hazardous chemicals must
Hazard Communication Program" material and appropriate hazard always be labeled. Therefore, it is
All workplaces where employees are warnings. Chemical manufacturers, important to designate someone to be
exposed to hazardous chemicals must have importers, and distributors are responsible for ensuring that the labels are
a written plan which describes how the required to ensure that every maintained as required on the containers in
standard will be implemented in that container of hazardous chemicals your facility, and that newly purchased
facility. Preparation of a plan is not just a they ship is appropriately labeled materials are checked for labels prior to
paper exercise - all of the elements must with such information and with the use.
be implemented in the workplace in order name and address of the producer or B. "Material Safety Data Sheets"
to be in compliance with the rule. See other responsible party. Employers Chemical manufacturers and importers are
paragraph (e) of this section for the purchasing chemicals can rely on the required to obtain or develop a material
specific requirements regarding written labels provided by their suppliers. If safety data sheet for each hazardous
hazard communication programs. The only the material is subsequently chemical they produce or import.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 57


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)


S-290
Distributors are responsible for ensuring when they return, so the telephone 31:9113
that their customers are provided a copy of system is simply an emergency based on the hazard categories (e.g.,
these MSDSs. Employers must have an arrangement. flammable liquids, corrosive materials,
MSDS for each hazardous chemical which In order to ensure that you have a carcinogens). Employees will have access
they use. Employers may rely on the current MSDS for each chemical in to the substance-specific information on
information received from their suppliers. the plant as required, and that the labels and MSDSs.
The specific requirements for material employee access is provided, the Information and training is a critical part
safety data sheets are in paragraph (g) of compliance officers will be looking of the hazard communication program.
this section. There is no specified format for the following types of Information regarding hazards and
for the MSDS under the rule, although information in your written program: protective measures are provided to
there are specific information 1. Designation of person(s) workers through written
requirements. OSHA has developed a non- responsible for obtaining and labels and material safety data sheets.
mandatory format, OSHA Form 174, maintaining the MSDSs; However, through effective
which may be used by chemical 2. How such sheets are to be information and training, workers will
manufacturers and importers to comply maintained in the workplace (e.g., in learn to read and understand such
with the rule. The MSDS must be in notebooks in the work area(s) or in a information, determine how it can be
English. You are entitled to receive from computer with terminal access), and obtained and used in their own
your supplier a data sheet which includes how employees can obtain access to workplaces, and understand the risks of
all of the information required under the them when they are in their work exposure to the chemicals in their
rule. If you do not receive one area during the work shift; workplaces as well as the ways to protect
automatically, you should request one. If 3. Procedures to follow when the themselves. A properly conducted training
you receive one that is obviously MSDS is not received at the time of program will ensure comprehension and
inadequate, with, for example, blank the first shipment; understanding. It is not sufficient to either
spaces that are not completed, you should 4. For producers, procedures to just read material to the workers, or simply
request an appropriately completed one. If update the MSDS when new and hand them material to read. You want to
your request for a data sheet or for a significant health information is create a climate where workers feel free to
corrected data sheet does not found; and, ask questions. This will help you to ensure
produce the information needed, you 5. Description of alternatives to that the information is understood. You
should contact your local OSHA Area actual data sheets in the workplace, must always remember that the underlying
Office for assistance in obtaining the if used. purpose of the HCS is to reduce the
MSDS. For employers using hazardous incidence of chemical source illnesses and
The role of MSDSs under the rule is to chemicals, the most important aspect injuries. This will be accomplished by
provide detailed information on each of the written program in terms of modifying behavior through the provision
hazardous chemical, including its potential MSDSs is to ensure that someone is of hazard information and information
hazardous effects, its physical and responsible for obtaining and about protective measures. If your
chemical characteristics, and maintaining the MSDSs for every program works, you and your workers will
recommendations for appropriate hazardous chemical in the better understand the chemical hazards
protective measures. This information workplace. The list of hazardous within the workplace. The procedures you
should be useful to you as the employer chemicals required to be maintained establish regarding, for example,
responsible for designing protective as part of the written program will purchasing, storage, and handling of these
programs, as well as to the workers. If you serve as an inventory. As new chemicals will improve, and thereby
are not familiar with material safety data chemicals are purchased, the list reduce the risks posed to employees
sheets and with chemical terminology, you should be updated. Many companies exposed to the chemical hazards involved.
may need to learn to use them yourself. A have found it convenient to include Furthermore, your workers'
glossary of MSDS terms may be helpful in on their purchase orders the name comprehension will also be increased, and
this regard. Generally speaking, most and address of the person designated proper work practices will be followed in
employers using hazardous chemicals will in their company to receive MSDSs. your workplace.
primarily be concerned with MSDS C. "Employee Information and If you are going to do the training
information regarding hazardous effects Training" yourself, you will have to understand the
and recommended protective measures. Each employee who may be material and be prepared to motivate the
Focus on the sections of the MSDS that "exposed" to hazardous chemicals workers to learn. This is not always an
are applicable to your situation. when working must be provided easy task, but the benefits are worth the
MSDSs must be readily accessible to information and trained prior to effort. More information regarding
employees when they are in their work initial assignment to work with a appropriate training can be found in
areas during their workshifts. This may be hazardous chemical, and whenever OSHA Publication No. 2254 which
accomplished in many different ways. You the hazard changes. "Exposure" or contains voluntary training guidelines
must decide what is appropriate for your "exposed" under the rule means that prepared by OSHA's Training Institute. A
particular workplace. Some employers "an employee is subjected to a copy of this document is available from
keep the MSDSs in a binder in a central hazardous chemical in the course of OSHA's Publications Office at (202) 219-
location (e.g., in the pick-up truck on a employment through any route of 4667. In reviewing your written program
construction site). Others, particularly in entry (inhalation, ingestion, skin with regard to information and training,
workplaces with large numbers of contact or absorption, etc.) and the following items need to be considered:
chemicals, computerize the information includes potential (e.g., accidental or 1. Designation of person(s) responsible for
and provide access through terminals. As possible) exposure." See paragraph conducting training;
long as employees can get the information (h) of this section for specific 2. Format of the program to be used
when they need it, any approach may be requirements. Information and (audiovisuals, classroom instruction, etc.);
used. The employees must have access to training may be done either by 3. Elements of the training program
the MSDSs themselves - simply having a individual chemical, or by categories (should be consistent with the elements in
system where the information can be read of hazards (such as flammability or paragraph (h) of this section); and,
to them over the phone is only permitted carcinogenicity). If there are only a 4. Procedure to train new employees at the
under the mobile worksite provision, few chemicals in the workplace, then time of their initial assignment to work
paragraph (g)(9) of this section, when you may want to discuss each one with a hazardous chemical, and to train
employees must travel between individually. Where there are large employees when a new hazard is
workplaces during the shift. In this numbers of chemicals, or the introduced into the workplace.
situation, they have access to the MSDSs chemicals change frequently, you The written program should provide
prior to leaving the primary worksite, and will probably want to train generally enough details about the employer's plans

58 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.7 OSHA hazard communication federal standard—1910.1200 (cont.)

S-290
in this area to assess whether or not a good On multi-employer worksites, has
faith effort is being made to train the employer provided other 31:9114
employees. OSHA does not expect that employers with information about
every worker will be able to recite all of labeling systems and precautionary
the information about each chemical in the measures where the other employers
workplace. In general, the most important have employees exposed to the
aspects of training under the HCS are to initial employer's chemicals?
ensure that employees are aware that they Is the written program made
are exposed to hazardous chemicals, that available to employees and their
they know how to read and use labels and designated representatives?
material safety data sheets, and that, as a If your program adequately
consequence of learning this information, addresses the means of
they are following the appropriate communicating information to
protective measures established by the employees in your workplace, and
employer. OSHA compliance officers will provides answers to the basic
be talking to employees to determine if questions outlined above, it will be
they have received training, if they know found to be in compliance with the
they are exposed to hazardous chemicals, rule.
and if they know where to obtain 5. "Checklist for Compliance"
substance-specific information on labels The following checklist will help to
and MSDSs. ensure you are in compliance with
The rule does not require employers to the rule:
maintain records of employee training, but Obtained a copy of the rule.
many employers choose to do so. This ______________
may help you monitor your own program
to ensure that all employees are Read and understood the
appropriately trained. If you already have requirements.
a training program, you may simply have ______________
to supplement it with whatever additional Assigned responsibility for tasks.
information is required under the HCS. ______________
For example, construction employers that Prepared an inventory of chemicals.
are already in compliance with the ______________
construction training standard (29 CFR Ensured containers are labeled.
1926.21) will have little extra training to ______________
do. Obtained MSDS for each chemical.
An employer can provide employees ______________
information and training through whatever Prepared written program.
means are found appropriate and ______________
protective. Although there would always Made MSDSs available to workers.
have to be some training on-site (such as ______________
informing employees of the location and Conducted training of workers.
availability of the written program and ______________
MSDSs), employee training may be Established procedures to maintain
satisfied in part by general training about current program. ______________
the requirements of the HCS and about Established procedures to evaluate
chemical hazards on the job which is effectiveness. ______________
provided by, for example, trade
associations, unions, colleges, and 6. "Further Assistance"
professional schools. In addition, previous If you have a question regarding
training, education and experience of a compliance with the HCS, you
worker may relieve the employer of some should contact your local OSHA
of the burdens of informing and training Area Office for assistance. In
that worker. Regardless of the method addition, each OSHA Regional
relied upon, however, the employer is Office has a Hazard Communication
always ultimately responsible for ensuring Coordinator who can answer your
that employees are adequately trained. If questions. Free consultation services
the compliance officer finds that the are also available to assist
training is deficient, the employer will be employers, and information
cited for the deficiency regardless of who regarding these services can be
actually provided the training on behalf of obtained through the Area and
the employer. Regional offices as well.
D. "Other Requirements" The telephone number for the OSHA
In addition to these specific items, office closest to you should be listed
compliance officers will also be asking the in your local telephone directory. If
following questions in assessing the you are not able to obtain this
adequacy of the program: information, you may contact
Does a list of the hazardous chemicals OSHA's Office of Information and
exist in each work area or at a central Consumer Affairs at 1-800-321-
location? OSHA (6742) for further assistance
Are methods the employer will use to in identifying the appropriate
inform employees of the hazards of non- contacts.
routine tasks outlined?
Are employees informed of the hazards
associated with chemicals contained in
unlabeled pipes in their work areas?

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 59


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.8 Emergency eyewash equipment standards

The American National Standards Institute (ANSI) has established an emergency eyewash and shower
equipment standard—ANSI Z358.1-1998—to give the minimum performance for eyewash equipment for
the emergency treatment of the eyes of a person who has been exposed to injurious materials.

ANSI Z358.1-1998 is a guideline widely accepted in industry and referenced by OSHA.

We’ve adopted the eyewash equipment recommendations that follow from the ANSI standard for plumbed
and self-contained eyewash units that are applicable for medical practices and other ambulatory care
settings.

Plumbed and self-contained eyewash equipment

Performance
• The organization will provide a means for a controlled flow of flushing fluid to both eyes simultane-
ously at a velocity low enough to be non-injurious to the user.

• Use eyewash units designed and positioned in such a way as to pose no hazards to the user.

• Protect nozzles from airborne contaminants. Removing such protection will not require a separate
motion by the operator when activating the unit.

• Use plumbed and self-contained units that are constructed of materials that will not corrode in the
presence of the flushing fluid. Protect stored flushing fluid against airborne contaminants.

• Plumbed and self-contained eyewash equipment will deliver flushing fluid to the eyes not less than
1.5 liters per minute (0.4 gpm) for 15 minutes. If the supply line contains shutoff valves for mainte-
nance purposes, make provisions to prevent unauthorized shutoff.

• The unit will provide enough room to allow the eyelids to be held open with the hands while the
eyes are in the flushing fluid stream.

60 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.8 Emergency eyewash equipment standards (cont.)

• The eyewash unit will provide flushing fluid to both eyes simultaneously. A test gauge for making
determination of a suitable eyewash pattern will be a minimum 10.16 cm (4 in.) in length with two
sets of parallel lines equidistant from the center. The interior set of lines will be 3.18 cm (1.25 in.)
apart and the exterior lines will be 8.26 cm (3.25 in.) apart. Place the gauge on top of the stream of
the eyewash. The flushing fluid should cover the areas between the interior and exterior lines when
the gauge is lowered not more than 3.81 cm (1.5 in.) below the fluid’s peak.

Control valve
• Use a control valve designed so that the flow remains on without requiring the use of the operator’s
hands.

• The valve will remain activated until intentionally shut off.

• The valve will be simple to operate and will go from “off” to “on” in 1 second or less.

• The valve will be resistant to corrosion from flushing fluid. The valve actuator will be large enough
to be easily located and operated by the user.

Manufacturer’s performance testing procedures


The manufacturer will certify plumbed eyewash units as follows:
• Connect a flow meter to the eyewash unit for testing, or provide other means of measuring flushing
fluid flow

• Open the valve on the eyewash unit and verify that it opens in one second and stays open

• Using the flow meter or other means, determine that the rate of flow is at least 1.5 liters per
minute (0.4 gpm), that the flushing streams rise to approximately equal heights, and that the flush-
ing fluid will wash both eyes simultaneously at a velocity low enough to be non-injurious to the user

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 61


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.8 Emergency eyewash equipment standards (cont.)

Installation of a plumbed unit


• The unit will be positioned with the flushing fluid nozzles not less than 83.8 cm (33 in.) and no
greater than 114.3 cm (45 in.) from the surface on which the user stands, and 15.3 cm (6 in.) mini-
mum from the wall or the nearest obstruction.

• Eyewash units will deliver flushing fluid. Equipment will have protection from freezing or freeze-pro-
tected equipment will be installed in areas where freezing exists.

• The supply line for plumbed units will provide an uninterruptible supply of flushing fluid at a mini-
mum of 0.207 megapascal (30 lb per sq in.) of flow pressure.

• Use units assembled and installed in accordance with the manufacturer’s instructions and accept-
able plumbing practices.

• After unit installation, operate the valve to determine whether it washes both eyes simultaneously
at a velocity low enough to be non-injurious to the user.

• Place eyewash units in accessible locations that require no more than 10 seconds walking time.
Locate the eyewash unit on the same level as the hazard and clear the path of travel of obstructions
that may inhibit the immediate use of the equipment. For a strong acid or strong caustic, place the
eyewash station immediately adjacent to the hazard. Contact the consulting physician or appropri-
ate professional for advice on the proper distance.

• Identify each eyewash location with a sign positioned so that it is visible within the area served by
the eyewash. Make sure the area around the eyewash is well lighted.

• Delivered flushing fluid temperature will be tepid (i.e., moderately warm or lukewarm). In circum-
stances where flushing fluid temperature can accelerate chemical reaction, consult a medical advi-
sor for the optimum temperature for each application.

62 OSHA R EGULATORY M ANUAL FOR H EALTHCARE


C HAPTER 1—H AZARD COMMUNICATION POLICY

Figure 1.8 Emergency eyewash equipment standards (cont.)

Maintenance and training


• Manufacturers will provide operation, inspection, and maintenance instructions with eyewash
equipment. Instructions for all emergency equipment will be readily accessible to maintenance and
inspection personnel.

• Inspect and maintain all eyewash units in accordance with the manufacturer’s instructions. Turn on
plumbed equipment weekly to verify proper operation.

• Instruct employees who may be exposed to hazardous materials in the location and proper use of
emergency eyewash units. Eyewash training will address holding the eyelids open and rolling the
eyeballs so flushing fluid will flow on all surfaces of the eyes and under the eyelid.

• Inspect all eyewash units annually to ensure conformance with ANSI Z358.1, section 5, requirements.

OSHA R EGULATORY M ANUAL FOR H EALTHCARE 63


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