Q&A: The experts explain GHS compliance
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February 16, 2017
Are you in compliance with OSHA’s chemical labeling standard?
Editor’s note: This Q&A was taken from the HCPro webinar, OSHA's Revised Hazard Communication Standard: Strategies for Training Staff and Implementing the GHS. Healthcare safety experts Marge McFarlane, PhD, CHSP, CHFM, HEM, MEP, CHEP, principal of Superior Performance, LLC, in Eau Claire, Wisconsin, and Paul Penn, president of EnMagine, Inc., emergency environmental health and safety management in Diamond Springs, California, provide their professional insight into implementing OSHA’s Globally Harmonized System of Classification and Labeling of Chemicals. To listen to the full program on demand, check out the HCPro Marketplace at www.hcmarketplace.com.
Q: Do facilities need to keep their MSDS (now SDS) on file for 30 years?
McFarlane: People who are using online systems have been relying on online systems to archive their MSDS. The OSHA standard has not changed. We still need to archive MSDS and now the SDS for 30 years plus the time of employment. I believe that in this electronic age we do not necessarily need to keep hard copies anymore. Why not scan them into a flash drive; have them in some computer file that can be readily accessed?
The whole purpose of saving MSDS and now SDS is that long-term health effects are the issue. In the old 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 until 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.
Paul Penn: 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.
Q: How can you find a good online SDS vendor?
McFarlane: 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? 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 about how many safety data sheets can I download for training purposes before I have an extra charge?
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.
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 you’ve got to have the redundancies 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.
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.
Q: Some manufacturers are taking a long time to comply. How do I get new safety data sheets from manufacturers?
Penn: Well, 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 saying, “When are we going to get this?” Work with your vendors, your distributors, and 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 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 that we’re starting to see SDSs coming out that have just changed the name. They’ve dropped the word “material” from the MSDS, 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: 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 SDS that matches that. If you continue to see chemicals with the old labels, you would expect potentially to see old MSDS. 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 gone proactively to the websites looking for SDS, and some companies have been sending them or I can download them at no charge even ahead of vendor delivery.
Q: How can you make sure temps, travelers, and contractors working at your facility are trained properly?
Penn: Those people that are within your organization, whether temps or travelers, need to be trained to work safely and effectively. Many of them are required to go through, for example, your new employee orientation, which is a great opportunity.
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: The challenge I see as I go around and talk to small clinics is they often have contracted housekeeping. Contracted housekeeping needs to have HazCom training as well as bloodborne pathogens training. 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.
If housekeepers come in, they need to be 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. 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.
Q: If I see a product with a new label and no SDS, what do I do?
McFarlane: 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. 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 SDS, 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.” You should not have to chase the new SDS. 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.
Q: Do facilities 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 an SDS 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.
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 were all kinds of stuff that somebody had brought in from home that had no training, no safety data sheet, no proper PPE, no procedure policy.
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 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.