OSHA: 'Right to Understand' means a duty to retrain
New Hazard Comm standard changes labeling
It's time to revamp your chemical safety training. An updated Hazard Communication Standard will change labels and safety data sheets on everything from cleaning products and sterilizing agents to hazardous drugs. And it requires employers to train workers on the new system before Dec. 1, 2013.
For hospitals, that means training a wide range of employees, including environmental service workers, nurses, laboratory workers, and maintenance workers. The new rule is designed to make safety information easier for them to understand.
In fact, the Occupational Safey and Health Administration is touting it as a "right to understand" standard a move forward from the "right to know" about chemical hazards in the workplace.
"The 'right to know' has protected millions of workers in its time, but we realize we must do more," said Secretary of Labor Hilda L. Solis as she released the new standard. The standard "will reduce confusion in the workplace, especially for low wage and low literacy workers.
"That understanding is powerful and perhaps the single most effective tool to protect workers," she said.
The revisions bring hazard communication in line with international requirements a Globally Harmonized System of Classification and Labeling of Chemicals. The standard involves new pictograms and "signal" words on labels as well as revised safety data sheets (SDSs). For example, irritants and dermal or respiratory sensitizers would be marked with a black exclamation point surrounded by a red diamond.
The current Material Safety Data Sheets (MSDS) are simply too technical and difficult to read, said OSHA administrator David Michaels, MD, MPH.
"Over the years, it became clear the Hazard Communication Standard wasn't adequate," he said. "The move to pictograms we think is a huge step forward. It will help workers who don't speak English as their native language or have low literacy."
Update your inventory of chemicals
As a first step, hospitals should review their inventory of hazardous chemicals, said Rick Cotter, president of RT Cotter and Associates in Kingston, MA, a consulting firm that helps hospitals prepare for Joint Commission Environment of Care surveys. His related company, MSDS Direct, helps hospitals manage their hazardous material systems.
Both the current and revised OSHA standards require employers to keep a list of known hazardous chemicals. There is no specific timeline for updating the list; employers are expected to keep it up to date as new chemicals are brought into the workplace, says Cotter.
A typical 150-bed hospital could have 1,500 to 2,000 items on the inventory, he says. You can monitor your chemical inventory by conducting spot checks pulling a chemical off the shelf, making sure it's on the inventory list and verifying that the safety data sheet is readily available.
It's a responsibility that shouldn't be left to department heads, who have other priorities, he says. "They don't have time. They're busy trying to manage patients," he said.
The new safety data sheets will have more detailed information, including sections on first aid, response to accidental release, exposure control, and proper handling and storage. They also will include the threshold value limits, or recommended exposure limits, of the American Conference of Government Industrial Hygienists, as well as any other established exposure limits.
Current material data safety sheets vary, said Cotter. "They were too technical in some places and not enough in other places," he says. "This is an excellent improvement in the formala so people really could understand."
To make sure you receive updated information on your products, Cotter suggested adding a statement to purchase orders requiring deliveries to be accompanied by safety data sheets.
The labels on hazardous products will be clear, with one of eight pictograms conveying the type of hazard. They will contain signal words: "Warning" for a less severe hazard and "Danger" for a more severe hazard. Labels also must contain a brief description of the hazard and the precautions that should be taken.
"The key date is 2016, when all employers that use or store chemicals must make sure their labeling of secondary containers complies with OSHA 2012 what's now called the 'Right to Understand' rule," said Pamela Dembski Hart, CHSP, BS, MT (ASCP), principal with Healthcare Accreditation Resources in Boston.
Teach employees about labels, safety
Manufacturers, importers and distributors have until 2015 to transition to the new labeling requirements, but employers have less than two years to re-train their workers.
Hospitals could conduct the training during other annual mandatory competency testing, or make it part of a safety fair, says Cotter. Or they might want to act more quickly with a special training program to teach employees how to decipher the new labels and what to expect from safety data sheets.
The new training may raise awareness of longstanding hazards. For example, employees don't always recognize the potential dangers from exposure to hazardous drugs, said Thomas Connor, PhD, a research biologist with the National Institute for Occupational Safety and Health (NIOSH) in Cincinnati and an expert on hazardous drugs.
"These are drugs, they help people, but they're still toxic chemicals," he said. "Over the years, it's been difficult to get that point across."
The Hazard Communication standard does not apply to drugs that are given in solid form to patients without being altered, such as pills or tablets. But it does apply to drugs that pose a risk of exposure when they're handled, mixed, or administered.
The standardized format of the safety data sheets will be helpful, said Connor: "Anything that brings attention to the hazards would be good for the workers."
[Editor's note: The Hazard Communication Standard is available at www.osha.gov/dsg/hazcom/index.html.]
It's time to revamp your chemical safety training. An updated Hazard Communication Standard will change labels and safety data sheets on everything from cleaning products and sterilizing agents to hazardous drugs. And it requires employers to train workers on the new system before Dec. 1, 2013.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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