OSHA S REVISED HAZARD COMMUNICATION STANDARD WHITE PAPER Editor s note: The following white paper is based on the question-and-answer session from HCPro s OSHA s Revised Hazard Communication Standard: Strategies for Training Staff and Implementing the GHS webcast, presented by Marge Mc- Farlane, PhD, MT (ASCP), CHSP, CHFM, HEM, MEP, CHEP, an independent safety consultant based in Wisconsin, and Paul Penn, MS, HEM, CHSP, CHEP, president/ceo of EnMagine, Inc., based in Placerville, Calif. For more information on this webcast, originally presented on January 8, 2014, visit http:// hcmarketplace.com/oshas-revised-hazard-communication-standard-1 or call customer service at 800-650-6787. What does OSHA s revised Hazard Communication Standard say about placards on vehicles? Paul Penn: Placarding is covered by the Department of Transportation and is really not covered under the Globally Harmonized System. There are linkages to them, but the focus is on here at the workplace and not on the placards in transport. But please be aware that those requirements remain, and it is important as you re training people to be aware of both the placarding and the labels as a separate topic. But because we re dealing with hazardous materials, those of you who are doing the training and are working at your loading docks and places like that to ensure that those placards are still there and are consistent with what s in the materials that you re receiving. Marge McFarlane: When I was working at the hospital, I would talk to materials management people about receiving formalin, which is a known carcinogen. What would they do if they dropped 5 liters of formalin? They said, Run quickly, which is an appropriate answer, but they also need to understand that as they are transporting these materials not using them, just transporting them from place to place, and especially when they take them in their cars and they transport them to off-site clinics, that they need to be aware of what is flammable, what is corrosive, what is hazardous. When you receive shipping containers, they may have GHS labels on the outside as well as the Department of Transportation placards that you see. The chemicals that I m thinking about the most are the ones that are used for boiler chemicals. Those have had the corrosive chemical on it for a very, very, very long time, and then they ve had an NFPA diamond. Now those will be consolidated, and they will look the same, because the answer is that they are very corrosive chemicals. They really remove the scale from inside boilers and mechanical equipment, but they re extremely hazardous to eyes.
2 OSHA S REVISED HAZARD COMMUNICATION STANDARD April 2014 Do I need to keep my MSDS for 30 years? Marge McFarlane: People who are using online systems have been relying on online systems to archive their material safety data sheets. The OSHA standard has not changed. We still need to archive material safety data sheets, and now the safety data sheets, for 30 years plus the time of employment. I believe that in this electronic age that we do not necessarily need to keep hard copies anymore. Why not scan them into a flash drive [or] have them in some computer file that can be readily accessed? The whole purpose of saving material safety data sheets, and now safety data sheets, is that long-term health effects are the issue. In the olden days, we used to use formaldehyde with abandon. We used it in the laboratory, we used it to clean dialysis equipment, and we did not really, really recognize the long-term carcinogenic effect of formaldehyde. We used to use benzene as a solvent till we realized that it caused bone marrow cancer. Again, if I come to you as my employer in 30 years because now I have cancer, and I am trying to link it back to a chemical that I used when I was in your employment, the 30-year saving of the material safety data sheets says, This is the knowledge we had about that chemical at the time you were using it. Formaldehyde has its own standard, and the exposure limits have become less and less and less and less so that employees are more protected by their employers when using formaldehyde. Now you say, Well, I don t use formaldehyde, and that may be true. But many laboratory operations use formalin, which is a 10% solution of formaldehyde. Sometimes people do not connect the word formalin with formaldehyde. They don t realize that they are the same product. They are both acutely toxic, and they are both carcinogens. Penn: Again, the point is that if somebody comes up with a medical condition down the road, they want to be able to trace back to see whether they can identify a correlation between the health consequences and the exposures.
April 2014 OSHA S REVISED HAZARD COMMUNICATION STANDARD 3 What should you look for in a good online SDS vendor? McFarlane: I am not in a position to recommend a vendor. I know that there are several online vendors that do what you need to do. How would you recommend a vendor? I guess I would interview them. I would find out do they have the chemicals that you need covered? How responsive will they be to your questions about spills and emergencies? Do they have a hotline number for you to access? Again, if you re managing these online and you have an incident, you re going to need to be able to access emergency information right now. So will they be able to do that for you? Then talk to them about their archiving policy. I would also ask the question, How many safety data sheets can I download for training purposes before I have an extra charge? Those are some of the things that I would discuss. OSHA is very, very clear that an online vendor is just fine. You can also use computers. You can put all of your safety data sheets in a folder on a computer. The caveat is that every worker directly needs to be able to access that. So the computer needs to be unlocked. The employee needs to be able to navigate to the section where the safety data sheet would be available. They would be able to read it, and without any barriers in the way. That is the challenge that I see for training. Penn: As we move toward a more electronic world, there are many benefits to having a high-quality online system to access those. Many of those online vendors also have toxicologists available to provide support during these events. But the caveat that Marge talked about is that you ve got to have the redundancies, [so] that if, for example, your computer line goes down, that there has still got to be a way to access it. Generally, that is done by a telephone call, and then it is faxed on demand. This brings up one of those interesting things that when OSHA actually issues a standard, they re really not sure what its actual impact is. It isn t until it s out there for a while and there are things such as interpretation letters that are written that there is clarity on this. In the beginning, when online vendors started coming out, there was a lot of consternation and confusion, but I believe that they do have a place in the industry, and they may then provide a very good-quality service. Obviously, here we re not here to recommend vendors, but there are several out there that are both comprehensive and have the backup. Again, they have toxicologists available 24 hours a day. They ve got redundant systems. I would make sure that you have those available, and I would not discount the issue these days of maintaining those safety data sheets on site. These are the things that are going to give you that redundancy. As an emergency manager, we always want to have low-tech backups. One of my rules of emergency management is the higher the level of technology, the greater the chance it won t work when you really need it.
4 OSHA S REVISED HAZARD COMMUNICATION STANDARD April 2014 What about temps, travelers, and contractors? Penn: Those people that are within your organization, whether temps, travelers, need to be trained to work safely and effectively, and that includes the Hazard Communication Standard. Many of them are required to go through, for example, your new employee orientation, which is a great opportunity. Those of you in the audience that do new employee orientation, raise your hand. It s a joy every week or two weeks or three weeks when you have to go out there and do this. But this is an opportunity for both your employees and the travelers and the temps to bring them up to speed on how these programs are being implemented within your organization. They are covered and need to be addressed, and it s just the smart and right thing to do because it doesn t matter where their paycheck comes from. They re still using these chemicals, and it is our responsibility to ensure a safe and healthful workplace. McFarlane: I think that there is possibly a more formal process in larger institutions, either big clinics or hospitals. The challenge I see as I go around and talk to small clinics so we re talking one, two, three, four, eight doctors in private practice and possibly part of a network where the doctors are sole practitioners or not incorporated necessarily what they have then is a clinic manager who is busy day to day trying to manage the clinic and the business aspect of the practice. They often have contracted housekeeping. I talk to them about contracted housekeeping. Contracted housekeeping needs to have HazCom training as well as bloodborne pathogen training. Now they can have the general information from whoever you re contracting with if they are a service. What I also see is they have a friend of a friend who she and her daughter come in and do housekeeping in small communities across the North Woods. They don t think that they re as important as those people whom they are paying regularly. OSHA is very, very clear about if you are providing the hazard, you need to provide the training. Again, it is chemical-specific. If housekeepers come in, they are using EPA-approved disinfectants. Those are the people I often see bring in products from home because they like the way it cleans, but they may not be EPA-approved for bloodborne pathogens. As Paul has stated in a previous lifetime, the properties of chemicals that make them useful make them hazardous. I think that they re used to cleaning, and they re focusing on cleaning, and they take pride in cleaning, but they may not understand the hazards, and they think that it doesn t apply to them. I see the contracted employees as being at risk.
April 2014 OSHA S REVISED HAZARD COMMUNICATION STANDARD 5 How do I get new safety data sheets? Penn: The best way is to have a good and close relationship with your vendors. Talk to them about how they are going to ensure that you are in compliance with the GHS. That means say, When are we going to get this? Work with your vendors, your distributors, the people you work with on a regular basis, and let them know that you are aware of GHS, and ensure that they are, too. Hopefully now that you ve gone through this webinar you will have sufficient information that you look at those SDSs with scrutiny, and see whether they are using the NFPA rather than the new system, and hold their feet to the fire. They may not be aware, as Marge said, that we re starting to see SDSs coming out that have just changed the name. They ve dropped the word material from the MSDSs, but the content has not really changed, and it s not in full compliance. My suggestion is work with your distributors, work with your vendors, and hold them responsible. If they are not being responsive to you, that s an indication of the quality of that vendor or distributor. McFarlane: Thanks, Paul. What I have heard from clinics as I tour is, How do I get a hold of all the SDSs? They think that they need to turn them over this very second. What Paul and I are here to say is that there is a timeline, and vendors do not have to have them out until June of 2015. So there may be some period of time when there is no transition yet. Again, the moment that you see a label that has a pictogram on it on a chemical, on a chemical box, that is the signal to you that there should be an updated safety data sheet that matches that. I think that would be not your warning property but your first alert. If you continue to see chemicals with the old labels, you would expect potentially to see old material safety data sheets. Even if they change the name to safety data sheets, they may not be in a consistent format. They will not have the pictograms necessarily on them. I have seen some people move toward adding pictograms even though the labels still have the NFPA diamond or the HMIS bars on them. Again, the whole point of the NFPA label is that it gives you a number rating that is opposite of the GHS standard. Those are the big training issues. As you see the labels, you will want SDSs to match. You will have a period of time to change these over. I have gone proactively to the websites looking for safety data sheets, and some companies have been sending them or I can download them at no charge even ahead of vendor delivery.
6 OSHA S REVISED HAZARD COMMUNICATION STANDARD April 2014 In your travels, how prepared were facilities for the December 1, 2013, staff training deadline? McFarlane: The answer is not. It sounds kind of scary, the whole GHS. Do we need to start over? This is so complex. I can t possibly have time to figure it out. I do the chemical training because it s other duties as assigned, and what I see is value in things like this webinar and other online applications from HCPro which break it down. What do I need to do? How do I need to start? I really emphasize what has not changed versus what has changed. When we take a look at what has changed, it s important for employee understanding, but it is just limited. The other piece I think is key is they think, I need all of these safety data sheets. The value of the standardized format with the hazards classified the same, the precautionary statements the same, the hazard warnings the same, when I get a safety data sheet for bleach, it won t matter what vendor I have because the warnings, the precautionary statements, the pictograms will all be identical. I don t know how many times I have seen material safety data sheets from different vendors, and the hazards are classified different. Some say you don t need to wear anything; some say you need to be fully suited up; some say you need an eyewash station even though nothing is stated in there. When you talk to the manufacturer, they say, Oh, we just kind of put that in for everybody. Again, with the GHS update and things being more standardized in the classification of the hazards so that everybody is using the same words for the same product for the same hazards, I think that the training will be in the end much more understandable, much more productive, and people will be able to really understand what s happening rather than, Yeah, yeah, yeah. Just let me take the test and sign me out. Penn: Well, I concur with Marge that the standardization is appropriate. I think she alluded to earlier that MSDSs in the old days were written on two extremes, either for somebody with a third-grade education or somebody with a PhD in toxicology. They were often not usable and not readable. There was information missing. There was information that was contradictory. I think this is a great move toward having a unified approach. I do want to emphasize that even though the SDSs will have the same information hopefully, that if you do change a vendor and you move from one bleach to another with another label, you need to make the transition. You need to have a new SDS for that new product. Even though the information will still be essentially the same, it needs to correlate to the product on site. If you re using bleach from ABC company, you move to XYZ company, you need to have all the products and labels from the XYZ company. Some of the larger institutions have been preparing for this and have implemented, but the vast majority of people are either unaware or are putting everything on ignore. The changes, some are significant, but they re not monumental. You can either phase it in or do it in one fell swoop, working with your vendors. I would say that within your organization, working with materials management and safety, environmental services, and engineering and those other folks that use the products is sit down and come up with a plan for implementation, and then follow that plan, and I think you will be okay. There will be bumps along the road, but in the long run I believe again we will be able to protect the public health, safety, and environment; our workers, our occupants, our patients, and it will be good in the long run. There will be bumps.
April 2014 OSHA S REVISED HAZARD COMMUNICATION STANDARD 7 Do I still need an updated chemical list? McFarlane: The answer simply is yes. An updated chemical list, in the laboratory it s annual; OSHA just says periodically for the HazCom standard. I still think with the ability of people to bring in different chemicals that an annual review of your chemical list is important. You want to make sure that the chemicals that you are using are on your list and that you have a safety data sheet to match as well as proper PPE and training, and that those chemicals that you are no longer using have been eliminated by a clean sweep or through a proper vendor, not just down the drain or not just in the trash. They need to go properly out to protect our environment. But what I see is that people keep bringing in chemicals. I toured a clinic, and I was helping them with their chemical list. I looked under a sink, and there was carpet cleaner, and there was all kinds of stuff that somebody had brought in from home that no training, no safety data sheet, no proper PPE, no procedure policy. It s kind of like, Why are these things here? Oh, we needed that for something that happened a long time ago. As soon as I see carpet cleaner, my concern always of course goes to bloodborne pathogens. It s kind of like, This is a spot remover for household carpets. This is not an appropriate product for bloodborne pathogen spills in a clinic with carpet. Again, you need some way to monitor the chemicals that you are using so you can protect the people. Penn: The only thing that I would add is just a little technique that I used to use in the hospital is we would often have, for example, an environmental services worker who was on limited duty who they know every nook and cranny of that facility. I would marry them up with, let s say, a student intern who was majoring in either environmental studies or occupational health. I would marry them up and basically instruct them to go into every room, every cabinet, every closet within the facility to take a look at those chemicals and to identify and list those so that we could get a handle, because as Marge says, these things show up from who knows where. Again, as she indicated, many circumstances where even though we looked for them in the past, we open up a cabinet, and there is a bottle of nitric acid with dust on it that is scary or things that have been out of date for years and years, or stuff that we had stopped using five years ago just somehow or another shows up. Staying on that chemical list and properly looking at it and ensuring that there is a relationship between what you have on site, and whether they re appropriate, and whether you have the appropriate SDSs, and people have been trained is the way to keep people safe within your organization.
8 OSHA S REVISED HAZARD COMMUNICATION STANDARD April 2014 If I see a product with a new label and no SDS, what do I do? McFarlane: That s exactly my point. Whoever is unpacking these chemicals out of their shipping box has to have the understanding. Now they may not be the people who are using these chemicals day to day. Again, awareness training that we ve talked about. You need to recognize the pictograms, recognize an SDS when you see it, and recognize the new labels. Again, awareness training needs to go universal, because everybody is going to be touching chemicals sooner or later, no matter what their position is in your organization. If I see the new label with no safety data sheet, my first call is to my vendor. I want to look in the box. It s possible that under the packing slip they ve included a safety data sheet. It s also possible that they have not and just said, Oh, you can go to the website and download it yourself. Paul s point to do you have a vendor that is responsive to your needs, and those are the people that I would look for. They should be providing this for you, and you should not have to chase the new safety data sheet. But it will be worth it in the end if you do have to chase it just so that you have the information so that you have the right training. Again, PPE, emergency response, and all of those precautionary statements are really important along with the signal words and the pictures for people to know day to day what [they are] working with. Want more GHS information? Don t be caught unprepared for OSHA s updated chemical labeling requirements! The newest book from HCPro s employee safety line provides anyone charged with employee safety with guidance about the latest regulations for keeping staff safe when handling dangerous chemicals. Video training to keep your staff safe! In just under 30 minutes, this video explains OSHA s revised Hazard Communication standard and trains your staff on the new Globally Harmonized System (GHS). $129 Product Code: OSHAGHS $199 Product Code: VOSHAGHSTV ORDER ONLINE OR BY PHONE TODAY! www.hcmarketplace.com 800-650-6787