9 October 2020
The Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard details how healthcare organizations should inform employees about any hazardous chemicals to which they may be exposed at work. A key element of the standard relates to Safety Data Sheets (SDS).
These informative documents are critical in keeping workers, patients and the environment safe. The following sections take a closer look at OSHA’s SDS requirements and how organizations can ensure consistent compliance.
A Safety Data Sheet communicates comprehensive information about a chemical, including its properties; physical, health and environmental hazards; and any protective measures or safety precautions that should be followed when handling, storing or transporting the material.
OSHA requires chemical manufacturers to provide an SDS to any entity who uses the hazardous chemical, such as healthcare organizations. In turn, healthcare organizations must ensure employees can quickly access the most up-to-date SDSs for hazardous chemicals used and stored in their workspace. The standards emphasize the importance of making SDSs detailed yet easy-to-understand. To that end, an SDS follows a prescribed, user-friendly format.
An SDS is divided into 16 sections that communicate the following information:
Employers, including healthcare organizations of all types, must provide employees with ready access to SDSs for the hazardous chemicals in their workplace. There are many ways to facilitate access. For example, employers may keep their SDSs in a binder, store them electronically, or work with a third-party like Stericycle to house them in the cloud.
OSHA is not prescriptive as long as employees have immediate access to the information without leaving their work area. Even if an organization chooses to store SDSs electronically, it should have a back-up available in case of a power outage or other emergency.
OSHA does not require an SDS for household consumer products used in the workplace provided they are used as a consumer would use them, following the same purpose, duration and frequency.
If an employee exceeds this level of exposure, then an SDS is warranted.
Employees should receive training when they are first assigned to work with a hazardous chemical to make sure they understand the risks and the practices that can keep themselves and their co-workers safe—before they start interacting with the material. They should also receive training when a new hazardous chemical is introduced into the work area if they have not been trained on that material to date.
Training must include more than just reading the SDS. Proper education describes the dangers associated with the chemicals in the work area, what can be done to minimize risk, how to respond to a spill, and how this work relates to the Hazard Communication Standard as a whole.
Training should be accessible and easy to understand. It should also include an opportunity for employees to ask questions to ensure they fully comprehend the information presented.
Organizations can conduct training by categories of hazard, such as carcinogens, sensitizers, and acutely toxic agents, so staff see the relationship between chemicals and have a broader understanding of how to remain safe. They can also weave SDS training into larger OSHA training as long as OSHA’s requirements are fully met.
A first step in complying with OSHA’s SDS requirements is to recognize the hazardous chemicals a healthcare organization has onsite. This may involve conducting a room-by-room inventory and listing all the chemicals present.
Once an organization has a detailed list, staff can check that the required SDSs are available and accessible. An organization may want to designate a specific person(s) responsible for obtaining and maintaining the SDS. If a required SDS is missing, the designated employee should ensure that it is made available.
It is also important to check that SDSs are current. Manufacturers will send an SDS the first time a chemical is delivered or after there is a change to the document. When a new SDS arrives, staff must compare it to the existing one to determine what has changed. The organization should have processes for broadly communicating any new information to staff.
Learn more about how Stericycle can help you ensure compliance with OSHA’s Safety Data Sheet requirements.
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