Compliance

OSHA’s Hazard Communications

Changes to Safety Data Sheets will impact your practice and ASC.

By Jolynn Cook, RN, COE, CASC

The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs), formerly Material Safety Data Sheets (MSDSs), for each hazardous chemical manufactured in order to communicate to consumers/users information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required by OSHA to be presented in a consistent user-friendly, 16-section format.

It is essential employees in ophthalmology be familiar with the format and understand the contents of the SDSs to ensure proper and safe handling of dangerous chemicals. Although OSHA compliance requires time and attention from management and staff, compliance is essential. The objective of OSHA is always to ensure the safety of employees by eliminating risk wherever and whenever possible.

New SDS Information

The new SDS includes information such as:

▪ The properties of each chemical▪ The physical, health, and environmental health hazards
▪ Protective measures when using the hazardous product
▪ Safety precautions for handling, storing, and transporting the chemical.

OSHA requires SDS preparers to provide specific minimum information. This information is located in Appendix D of 29 CFR 1910.1200. The SDS preparers may also include additional information.

Section Legend

The following information is taken from the OSHA guidelines regarding the Safety Data Sheet:

Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., firefighting). This information should be helpful to those that need to get the information quickly.

Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element. The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies.

Employee training is now required on the new changes to the Hazard Communication Standard, beginning in December 2013.

Employers must ensure that SDSs are readily accessible to employees. For more information: 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.