Compliance

Develop your hazard communication plan

Make sure you are current with 2015 changes.

BY C. JOLYNN COOK, RN

Two primary OSHA standards apply to the ophthalmic practice: the Bloodborne Pathogens Standard and the Hazard Communications Standard (HCS).

This article focuses on recent changes required by the HCS revision of 2012. Most of this standard is now in effect, so you must be compliant with the required changes should you have an OSHA investigation.

HazCom overview

HazCom 2012 is the HCS update published in 2012. Your practice likely began implementing HazCom 2012 in December. The updates required by HazCom 2012 should have been fully implemented in your practice on June 1, 2015. The purpose of the change was to provide globally recognized labeling (formally the Globally Harmonized System, or GHS) to ensure safe handling of toxic products by the end user. The additional benefit was to positively impact the trade industry.

New labeling requires “pictograms” that can be universally recognized to indicate when a hazardous material is dangerous, toxic or requires special handling and storage, such as a flame to indicate “flammable.”

Manufacturers are required to affix appropriate labels on all containers.

Changes to previous standard

For many years, practices and ambulatory surgery centers made the Material Safety Data Sheets (MSDS) available to employees. These detailed the ingredients contained in various products, such as cleaning agents, that may cause harm if an employee used it incorrectly or came into direct contact with the chemical. The MSDS sheets were provided by the chemical manufacturer.

With the 2012 HCS changes, small employers, including ophthalmic practices, must change from the previous MSDS sheet to the new safety data sheet (SDS) and provide safety/first aid information on hazardous chemicals in the work place. For example, when special safeguards or safe-handling practices are required, such as gloves, goggles, respirators and eye wash stations, the practice is required to ensure that personal protective equipment is available to the employee when working with a hazardous chemical, such as cleaning products.

For products used in your office or surgery center for cleaning, contact the vendor to obtain a new SDS sheet and replace the existing MSDS sheet for that product. Practice managers must obtain labels and SDS sheets from the manufacturer of the product and make this information available to any employee using the chemical products. Consider combining all safety data sheets in a three-ring binder and keeping the binder easily accessible for quick reference on safe handling or use of products to protect employees or other users.

Be aware of deadlines

OSHA provides the following online specific information to comply with deadlines (See “HSC compliance deadlines,” page 26):

“By December 1, 2013, you must train your employees about the format and presentation of the SDSs that they will be seeing in the workplace. Over the course of several years, your suppliers will be updating labels and SDSs to comply with the new requirements. It is therefore important to insure [sic] that you and your employees are able to access and use the information provided in the new approach. All new labels and SDSs must be completed by June 1, 2015; however if you order from a distributor, you may receive labels compliant with HazCom 1994 (the Hazard Communications Standard issued in 1994) until December 1, 2015. If an employer identifies new hazards after December 1, 2015, due to the reclassification of hazardous chemicals, it has six months until June 1, 2016, to ensure those hazards are included in the Hazard Communication Plan for the practice.”

Regardless of your practice’s size, you must comply with the HSC by developing a hazard communication plan. OSHA provides a Bloodborne Pathogens Standard and Hazard Communications template that practices can adapt (https://www.osha.gov/Publications/osha3186.html — the hazardous communication standard appears later in the document). 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.