Hazardous chemicals exist all around us and the workplace is no different. While you may be exposed to some of the same chemicals at your house as you would at your workplace, OSHA requires that you follow certain regulations to identify and be protected from these substances. The Hazardous Communication System (HCS) for chemical safety has aligned with the Globally Harmonized System (GHS). Under the HCS a chemical inventory (comprehensive list) must be kept up to date with all the hazardous chemicals including, but not limited to: cleaners, lotions, soaps, and medications. The chemical inventory should not include medications that are in pill/tablet form, nor personal use items. Be sure that if any new products are purchased for the office that they are added to the chemical inventory under the Chemical Inventory, Advisory & SDS tab. If you no longer use a product in your office draw a single line through the product so it can be removed from your chemical inventory upon annual update. Remeber, even if a chemical substance is removed from the practice and the chemical inventory, that SDS must be retained within the practice for the term of employment plus thirty years for any employee exposed to that chemical during their employment with your practice — essentially forever!

Safety Data Sheets

Safety data sheets (SDS) are required to be on file for all of those items included in your chemical inventory. They present necessary identification, safety, and disposal information to the reader and are broken down into 16 different standardized categories:

1. Identification
2. Hazard Identification
3. Composition/Information on Ingredients
4. First Aid
5. Firefighting
6. Accidental Release Measures
7. Handling & Storage
8. Exposure Control/Personal Protection
9. Physical & Chemical Properties
10. Stability & Reactivity
11. Toxicological Information
12. Ecological Information
13. Disposal Considerations
14. Transport Information
15. Regulatory Information
16. Other Information

If you ever need more information about a product in your office, always check your SDS compendium. If you are an office of platinum level service, they can be found on the disk in your OSHA binder under the Chemical Inventory, Advisory & SDS tab. SDS need to be kept up to date, so if any changes are made to the SDS by the manufacturer your SDS also needs to be updated. For platinum clients, we take care of your SDS updates for you! Be sure to keep your chemical inventory up to date so we can keep your SDS disk up to date. Again, archive the old versions if you are maintaining your SDS in either electronic or print formats.

Staying Safe

In order to keep everyone safe within your office, be sure that you are familiar with the hazards of the substances used within your office. Identifying the hazards and following safety protocols is important for chemical safety. Always wear the personal protective equipment (PPE) identified in the SDS whenever using the substance and be sure that spills are cleaned up properly and promptly when they occur. Always dispose of chemicals and contaminated items in accordance with local guidelines.

Secondary Containers

Any time a product on your chemical inventory is placed into a container that does not have the manufacturer’s original labeling on it, the container must be labeled. Most substances are clear colorless liquids. Lets say you have three bottles, one contains diluted bleach water, one contains rubbing alcohol, and one contains plain water. If none of these bottles have labels on them, how do you decide between which one to use to clean the toilet and which one to rub on your patient’s skin? In addition to that, how do you know what will happen if you splash each one in your eye or whether you need to keep the container away from that electrical outlet or burning candle? Maybe this may seem somewhat silly to you, but the idea is there should not be any question on what is in the bottle and what dangers exist. In order to do this, there are specific labeling requirements that must be met to ensure that all of the necessary information is on the secondary container. The label will need to contain the name of the product, signal word, hazard pictograms, and the full hazard and precautionary statements as described in the SDS. Contact us for any of your secondary container label needs! The approved pictograms can be found below along with descriptions of what each pictogram represents.

GHS Labels

The new labeling system includes the following pictograms to identify the hazards associated with a substance. Be certain you and your team are familiar with these pictograms and their meanings. The table includes some examples of pictograms and possible statements you may see. For example, the skull and crossbones means that the substance is toxic. It tells you not to eat, drink, or smoke when using it to avoid accidental harmful exposure.

The HCS was modified in late 2013, and your final date for compliance was June 1, 2016. As always, if you have any questions, please do not hesitate to reach out to our offices!