Compliance

Out With Old OSHA regulations

Material safety data sheets and labeling changes will require retraining, revisions.

By Jolynn D. Cook, RN, COE, CASC

Practices and many industries nationwide maintain Material Safety Data Sheets (MSDS) documents providing product information to employees in the event the employee comes into contact with a hazardous substance. In an ophthalmic practice, this would include products used in cleaning and sterilizing. Whether an employee is a construction worker or an ophthalmic technician, the work area must be free of hazards and it is incumbent upon the employer to provide adequate protection.

Fortunately, in ophthalmology practices, the risk of exposure to hazardous chemicals is limited. Regardless of the low risk, a practice or ASC must provide a list of hazardous chemicals in the workplace along with instructions on how to safely handle them.

As part of the practice’s Hazardous Communications Plan in the OSHA Manual, the practice provides notification and information to the employee by documentation on MSDS’s. Each product has an individual MSDS. For example, glutaraldehyde solutions are commonly used for cleaning and sterilizing ophthalmic instruments. The practice is required to have an MSDS listing the chemical compounds contained within the cleaning or disinfecting solution along with appropriate first aid, in case an employee splashes chemicals onto her or his skin or eyes or ingests or inhales the product.

Should an OSHA inspector visit the practice/ASC, the inspector will review the MSDS sheets for products used and request to see the personal protective equipment for proper and safe handling of hazardous chemicals as described on the MSDS.

Effective December 2013, ophthalmic practices and ASCs must provide training to employees on the new label elements and safety data sheet (SDS) format that will replace the MSDS sheets industry and ophthalmology have used for years. Furthermore, OSHA has modified the Hazard Communication Standard (HCS) to adopt the Globally Harmonized System (GHS) to improve the safety and health of workers through more effective communications on chemical hazards.

The GHS Approach

The GHS is an international approach to hazard communication, providing agreed upon criteria for classification of chemical hazards and a standardized approach to label elements and SDS’s. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations and stakeholder groups. It is based on major existing systems around the world, including OSHA’s Hazard Communication Standard and the chemical classification and labeling systems of other agencies.

OSHA requires employees be trained on new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 2013. Full compliance with the final rule will begin in 2015.

Three areas scheduled to see changes include:

■ Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure evaluations of hazardous effects are consistent across manufacturers and that labels and safety data sheets are more accurate as a result.

■ Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.

■ Safety Data Sheets: SDS’s will now have a specified 16-section format.

The GHS does not include harmonized training provisions, but recognizes training is essential to an effective hazard communication approach. Workers be re-trained within two years of the publication of the final rule.

OSHA believes American workplaces will soon receive labels and SDS’s consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDS’s. It is important to ensure employees begin to see the new labels and SDSs in their workplaces, be familiar with them, understand how to use them and access the information effectively.

More information is available on OSHA’s Web site at www.osha.gov. OP

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.