Health & Safety Insights

One way your healthcare facility drives patient safety and quality care forward is by managing its chemical risks. However, did you know that compliance with OSHA’s Hazard Communication (HazCom) standard gives you the power to bring down these risks?

That’s because with HazCom, under 29 CFR 1910.1200, you have a standardized approach for communicating chemical hazards and safety procedures with workers. How you convey this information is important because it’s your workers who are the ones that must handle and store chemicals properly to lessen your risks and provide the safest and most effective care.

 

Hazardous chemicals abound in healthcare settings

In your facility, workers might deal with so-called hazardous chemicals, hazardous materials, hazardous substances, hazardous drugs, medical gases, radioactive materials, or hazardous wastes. No matter the name you give these chemicals, you find them everywhere you turn at your healthcare facility. That’s from the operating room, radiology department, and ambulatory vehicles to the food service, laundry, and maintenance shop.

The abundance of chemicals — most of them hazardous — poses a major risk to your healthcare organization. If chemicals are not managed “by the book,” then your patients, workers, visitors, and the community face exposure that can cause injury and illness, and even death.

Unfortunately, 1,700 occupational injuries and illnesses with days away from work occur in healthcare (and social assistance) on average each year due to chemicals and chemical products. If your workers are not sure how to handle these hazardous chemicals, their risk of injury and illness only increases.

 

HazCom compliance can help

Many workers in healthcare may be exposed to hazardous chemicals in day-to-day operations or in a foreseeable emergency. OSHA says these workers have the right to know and understand the hazards of the chemicals they’re exposed to at work and how to protect themselves. So, the HazCom standard requires that employers:

• Develop, implement, and maintain a written HazCom program;
• Include a list (or inventory) of non-exempt hazardous chemicals in the written program;
• Maintain safety data sheets (SDSs) for non-exempt hazardous chemicals;
• Ensure containers of non-exempt hazardous chemicals are labeled; and
• Train and inform workers on the non-exempt hazardous chemicals in their work areas.

Effective hazard communication not only helps to protect your workers from harm but your facility too from OSHA fines and accreditation survey failures. In fiscal year 2024, OSHA found almost two HazCom violations per inspection when it went to healthcare establishments. The organization that accredits your establishment for Medicare and Medicaid purposes (an accreditation organization or AO) may also be on the lookout for OSHA HazCom noncompliance during regular surveys of your facility.

 

Three surveyed pillars of HazCom

All HazCom provisions are important, but let’s talk about three that are touched on by accreditation standards dealing with the risks of “hazardous materials and waste.” Those three include the chemical inventory, SDSs, and container labeling.

Accreditation standards may word things more broadly than OSHA, requiring that your organization:

• Maintain an inventory of materials and waste,
• Have SDSs for materials and waste, and
• Label each container of materials or waste with the identity and hazards.

Don’t let this “simple” language lull you into thinking “anything goes.” Surveyors will cite if they stumble on OSHA HazCom failures.

 

1. Chemical inventory

HazCom requires you to create a list of non-exempt hazardous chemicals at work, and your workers have a right to see the inventory upon request. At a minimum, this inventory must be kept using the product identifier of each covered chemical. This is the product name, common name, or chemical name. It’s the same identifier found on both the SDS and container label.

The best way to prepare your inventory may be to do a walkthrough of the site. It’s easy to think of chemicals as being only liquids in containers. However, HazCom covers chemicals in all forms — liquids, solids, gases, vapors, fumes, and mists — whether they’re “contained” or not.

Not all hazardous chemicals are covered by the HazCom standard. OSHA provides exemptions at 1910.1200(b)(6). Some of these exempted hazardous chemicals may be in your healthcare facility. Take caution, however. Accreditation standards may mandate that your chemical inventory include “all” local-, state-, and federal-regulated materials, not just the ones covered by OSHA 1910.1200.

In other words, a surveyor may cast a wider net for your chemical inventory than OSHA would. That means things like pills/tablets for direct administration to patients, ionizing radiation, hazardous waste, and bloodborne pathogens may get pulled into chemical inventory requirements for accreditation, even though OSHA does not require them on the inventory.

Interestingly, The Joint Commission suggests considering ANY material that “could result in adverse exposure.”  The organization points to chemicals regulated not only by OSHA but also EPA and DOT for purposes of the chemical inventory. Yet, The Joint Commission allows the hazardous waste manifest to act as the inventory for hazardous waste.

A small healthcare facility might develop a chemical inventory for the entire facility, while a larger one might compile lists by work area and put them together to create the inventory for the facility. Regardless how you maintain it, be sure to keep this inventory current.

 

2. Safety data sheets

SDSs are the primary means of communicating comprehensive information about a hazardous chemical. You could say the SDS is the source of truth. As a healthcare employer, you must have an SDS for each hazardous chemical that is not otherwise exempted at 1910.1200(b)(6) when workers are exposed to it. If you do not receive an SDS from the chemical manufacturer or distributor upon initial shipment, you cannot use the chemical until you obtain the SDS.

SDSs must be in English. If you have workers who only speak/read languages other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication in both English and other languages.

SDSs must also be readily accessible to workers in their work areas through each work shift. OSHA allows SDSs to be maintained in paper or electronic format, and there must be no barrier to access. Examples of access barriers include keeping SDSs in a locked cabinet or having to request one from a supervisor.

If you maintain electronic SDSs, workers must be trained on how to use the system. In addition, if access to SDSs is provided electronically, you must have an adequate backup system in place in the event of a power outage, equipment failure, or other emergency involving the primary electronic system. During a worker medical emergency, SDSs must be immediately available to responding medical personnel.

 

3. Container labels

Container labels are also critical because they may be the first source of limited information that a worker sees about a particular chemical at work. A label must be on the immediate container of every hazardous chemical in your workplace when the chemical is not exempted at 1910.1200(b)(5) or (b)(6). Again, accreditation standards may cover materials that are otherwise exempted by OSHA HazCom, so review the standards to be sure you meet your surveyor’s expectations.

The labels you receive on shipped containers of hazardous chemicals (and containers leaving your facility) must have the following information, but supplemental information may also appear:

• Product identifier;
• Signal word;
• Pictogram(s);
• Hazard statement(s);
• Precautionary statement(s); and
• Name, U.S. address, and U.S. phone number of the responsible party.

For containers that arrive at your facility properly labeled by the supplier, maintaining that label is the best and easiest option. Still, OSHA allows you to relabel these containers with simpler “workplace” labels per 1910.1200(f)(6). “Secondary containers,” or containers of chemical transferred from a primary container, must have a workplace label, unless the container is for “immediate use” as defined by the HazCom standard.

According to paragraph (f)(6), workplace labels must have at least:

• The label information required on shipped containers minus the responsible party information; or
• A product identifier and words, pictures, and/or symbols that convey the general information regarding the hazards of the chemical.

Some chemical containers are so small they might arrive at your door without a complete HazCom shipping label on them. Instead, the immediate outer package provides the full label with the six required label elements. These small containers must be stored in the immediate outer package that bears the full label when not in use.

 

Final thoughts

To ensure the safety and health of your healthcare workers and a lowered chemical risk level at your facility, chemical hazard information must be available and understandable. OSHA’s HazCom standard provides a required framework to relay that information to workers so they can better manage hazardous chemicals. OSHA HazCom is even recognized and expected by AOs. What’s more, a stable workforce with fewer chemical-related injuries and illnesses creates a healthcare setting conducive to patient confidence and satisfaction.

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