A review of OSHA’s Hazard Communication Standard.

Employee safety should be a priority for practices. Routine work performed in the ophthalmic practice may require employees to work with hazardous chemicals (i.e., cleaning products, chemicals used to clean surgical instruments, and other surface cleaners). Optical labs may also use chemicals, depending on the extent of lab services offered.

The purpose of the Hazard Communication Standard (HCS) is to communicate information to employees concerning chemical hazards in the workplace and instruct employees on appropriate protective measures to take when working with hazardous chemicals. Manufacturers are responsible for determining a chemical’s hazards, with their findings conveyed in the product’s safety data sheet (SDS). Chemical manufacturers, distributors, or importers must also send an SDS sheet with initial shipments (and with initial shipment whenever the SDS is updated).

As part of their hazard communication program, practices and ASCs are required by the Occupational Safety and Health Administration (OSHA) to educate and inform employees of hazards through SDSs. HCS education must be part of the practice’s OSHA training, which is provided upon hire and via annual employee retraining.

By June 1, 2016, ophthalmic practices needed to update the HCS information for employee training to facilitate employee understanding of the hazards associated with the chemicals in their workplace by requiring the implementation of: (1) pictogram labeling and (2) a standardized format for SDSs, previously known as material safety data sheets (MSDSs).

New SDS format

The HCS requires new SDSs be in a uniform format, including the sections, headings, and associated information listed below provided by OSHA:

Section 1 — Identification: Lists product identifier; manufacturer or distributor name, address, and phone number; emergency phone number; recommended use; and restrictions on use.

Section 2 — Hazard(s) identification: States all hazards regarding the chemical and required label elements.

Section 3 — Composition/information on ingredients: Provides information on chemical ingredients and trade secret claims.

Section 4 — First-aid measures: Summarizes symptoms/effects (both acute and delayed) of chemical exposure, along with required treatment.

Section 5 — Fire-fighting measures: Outlines suitable fire extinguishing techniques and equipment, as well as chemical hazards that can result from a fire.

Section 6 — Accidental release measures: Lists the steps to take in the event of a chemical spill, including proper emergency procedures, protective equipment, and methods of containment and cleanup.

Section 7 — Handling and storage: Details the precautions for safe handling and storage, including incompatibilities.

Section 8 — Exposure controls/personal protection: States OSHA’s permissible exposure limits (PELs) along with any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS (where available); appropriate engineering controls; and personal protective equipment.

Section 9 — Physical and chemical properties: Lists the chemical’s characteristics.

Section 10 — Stability and reactivity: States chemical stability and the possibility of hazardous reactions.

Section 11 — Toxicological information: Lists routes of exposure, related symptoms, acute and chronic effects, and numerical measures of toxicity.

Section 12 — Ecological information*: Explains how the chemical might affect the environment and the duration of the effect.

Section 13 — Disposal considerations*: Describes safe handling of wastes and methods of disposal, including the disposal of contaminated packaging.

Section 14 — Transport information*: Outlines the packing, marking, and labeling requirements for hazardous chemical shipments.

Section 15 — Regulatory information*: Indicates regulations that apply to the chemical.

Section 16 — Other information: Lists the date of preparation or last revision.

Careful analysis of chemicals used by employees will reveal those that have low exposure limits, are highly volatile, or are used in large quantities or in unventilated spaces. Identify activities that may result in an exposure, and provide the appropriate personal protective equipment for using the chemical.

While most eyedrops and treatments are not considered toxic, ophthalmic mitomycin C is a toxic and potentially hazardous chemotherapeutic drug. It must be handled with care and disposed of properly in a chemotherapy disposal container, according to the American Society of Ophthalmic Registered Nurses’ tipsheet for handling, use, and disposal of ophthalmic mitomycin C.

Access to SDSs

The ophthalmic practice is required to retain the SDSs on hazardous products. Employers must ensure that SDSs are readily accessible to employees (typically in a three-ring binder), listing the hazardous products and other chemicals used within the facility.

An SDS sheet must be available on each of the listed chemicals. When an SDS sheet is unavailable, contact the distributor or go online to find the related SDS sheet for each product.

The most important information to have is emergency care for exposure. Meanwhile, employers must provide all required proper personal protective equipment for routine handling of chemicals and access to emergency treatment necessary to ensure the safety of each employee.

Conclusion

By following the recommendations above to inform employees of the potential risks and proper protocol when handling potentially dangerous chemicals, you will remain compliant and ensure your workplace is a safe environment. OP

* Other agencies will regulate this information, so OSHA will not enforce these sections.

Ms. Cook is a senior consultant with BSM Consulting. She is a registered nurse with significant experience in ASC and ophthalmic practice management. Email her at jdcook@bsmconsulting.com or call 814-715-7584.