Compliance Corner

OSHA Compliance and the Ophthalmology Practice

Replace MSDS with SDS (Safety Data Sheets) by year end.

By Jolynn Cook, RN, COE, CASC

Part two of a two-part series

Last issue, “Compliance Corner” reviewed complying with Occupational Health and Safety Administration (OSHA) programs and developing an exposure control plan.

The second of this two-part series will focus on changes that became effective in 2012 and must be implemented by year end, requiring employers to update the Hazardous Communication Standard (HCS) in the ophthalmic practice.

Chemical Safety

To ensure chemical safety, the identities and hazards of any chemicals in use must be available and understandable to workers. In 2012, OSHA modified the Hazard Communication Standard of 1994 (HazCom 1994) to adopt the Globally Harmonized System (GHS) to improve the safety and health of workers through more effective communication than was previously in place. Compliance with the updated communications standards are required by December 1, 2013.

Globally Harmonized System

The original hazardous communication standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. While the available information has been helpful in improving employee safety and health, a more standardized approach to classifying the hazards and conveying the information will be more effective, and provide further improvements in American workplaces. The Globally Harmonized System (GHS) provides such a standardized approach, including label elements assigned by hazard class and category.

The goal of OSHA is to enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals. In addition, the safety data sheet requirements establish an order of information that is standardized. The revised format of the safety data sheets will enable employers, workers, health professionals, and emergency responders to access the information more efficiently and effectively, increasing their utility.

If you have not done so, replace MSDS sheets with “Safety Data Sheets” or SDS. This information is required by OSHA to communicate information regarding safe handling and first aid when using toxic/hazardous chemicals in your office. The revised HazCom 2012 requires that the information on the SDS be presented using specific headings in a specified sequence. Employers are required to train employees on the SDS information by December 1, 2013. The information required on the safety data sheet (SDS) will remain essentially the same as that in the current Hazardous Communication Standard of 1994. HazCom 1994 indicates what information has to be included on an SDS, but does not specify a format for presentation or order of information.

HazCom 2012 provides the headings of information to be included on the SDS and the order in which they are to be provided. The SDS format is the same as the ANSI standard format which is widely used in the United States and is already familiar to many employees. OP

Information related to the revised Hazard Communication Standard can be found on OSHA’s Hazard Communication Safety and Health Topics page, located at www.osha.gov/dsg/hazcom/index.html.

Ms. Cook is the Administrator of the Laurel Eye Clinic and the Laurel Laser & Surgery Centers. A Certified Ophthalmic Executive and Certified Administrator Surgery Center, she is a registered nurse and also has a degree in Health Care Administration.