HAZARD COMMUNICATIONBY HARRY H. HOLDORF

HAZARD COMMUNICATION IS NOW GHS HAZARD COMMUNICATION

GLOBALLY HARMONIZED HAZARD COMMUNICATION STANDARD CFR 1910.1200 OSHA Hazard Communication Standard

This program was established so that employee’s will be informed of the contents of the Hazard Communication Standard, the hazardous properties of the chemicals with which they work, safe handling procedures and the measure to take to protect themselves from hazardous chemicals.

This standard was revised. The changes have been made to labeling requirements, MSDSs are now referred to as SDSs with added sections, and training requirements have been revised to align with the UN Globally Harmonized System of Classification and Labeling of Chemicals.

EFFECTIVE COMPLETION DATE FOR LABELING AND SDS REQUIREMENTS

Use the following checklist to help you comply with OSHA HCS 2012:• Audit your chemicals: conduct a

physical audit of all chemicals in the workplace

• Confirm the use of workplace labels: as you conduct your inventory, ensure all containers are properly labeled

• Obtain updated supplier SDSs: contact the manufacturer for a current SDS for each chemical in the workplace

• Distribute your supplier SDSs: ensure your chemical users have FREE, unlimited access to the updated SDSs

• Train your employees: update your existing hazardous chemical training program to include the GHS data elements and format of the SDS

AUDIT LIST FOR COMPLIANCE

HAZARDOUS CHEMICALS INVENTORY LIST (HCI)A representative from each clinic/lab will maintain up a list of all products that contain hazardous chemicals used in their clinic or laboratory

This will be referred to as the hazardous chemicals inventory list (HCI)

This list will be kept in front of the SDS book for reference

This list will be updated as new chemicals are introduced into or removed from the clinic

SAFETY DATA SHEETS(SDS) SDSs are detailed information bulletins prepared

by the manufacturer or supplier of any product that contains a chemical deemed to be hazardous

The SDS has 16 sections:Identification, Hazard(s) Identification,

Composition/Information on Ingredients, First-Aid Measures, Fire-fighting Measures, Accidental Release Measures, Handling and Storage, Exposure Controls/PPE, Physical and Chemical Properties, Stability and Reactivity, Toxicological Info, Ecological Info, Disposal Considerations, Transport Information, Regulatory Information, and Other Information

SAMPLE SDS

SDS

If an SDS is not available refer to the online SDS Public Service Library at http://www.chemquik.com/scripts/main.asap

LABELS• Labels will list the chemical identity of the material, appropriate hazard warnings and the name of the manufacturer

• The manufacturer is responsible for labeling the original container, however, it is the ultimate responsibility of the PM or lab supervisor

• Professional products that are regulated by the FDA are exempt from labeling except when transferred to a secondary label

LABELS FOR HAZARDOUS CHEMICALS Labels for hazardous chemical must contain:

Name, address, and telephone number

Product identifier

Signal word

Hazard statement(s)

Precautionary statement(s)

Pictogram(s)

OSHA HCS 2012 LabelsUnder OSHA HCS 2012, chemical manufacturers and importers must label their chemical containers with the applicable GHS elements. In turn, employers must convey these GHS elements on the workplace label for each hazardous chemical. These GHS elements include:• Signal Word: “Danger” or “Warning”

indicates the severity of the hazard.• GHS Pictograms: convey the health,

physical and environmental hazard information assigned to a specified GHS hazard class and category.

• Health and Physical Hazard Statements: describe the nature and degree of the stated hazard.

• Precautionary Statements: describe measures to minimize or prevent effects from exposure or improper storage of the hazardous chemical.

GHS LABELS & PICTOGRAMS

GHS LABELING REQUIREMENTS VIDEOCLICK ON THE HYPERLINK BELOW

https://www.youtube.com/watch?v=RvQNf1Y7E84&noredirect=1

SAMPLE GHS LABEL

SAMPLE LABEL

SAMPLE BLANK LABEL SUPPLIES

SECONDARY LABELSChemicals transferred to a secondary container need to be labeled

Examples of secondary containers include: alcohol, bleach, disinfectant, radiographic chemicals

Every container that you place a chemical in needs to be labeled…including, ultrasonic cleaners and radiographic processors

UPDATED TRAINING

Hazard Communication training must be updated to include the new label and SDS formats and how to implement these changes

STORAGE AND DISPOSAL OF HAZARDOUS CHEMICALS

STORAGE CONTAINERS

Hazardous waste storage containers must be in good condition, free of leaks and compatible with the material stored in them

The container should remain capped when not in use

If the container should begin to leak, place in a larger non-leaking container, transfer to another container and call the safety office at 433-7556 is needed

All containers must be marked with the words “waste” or “spent”

Kept near the site of generation and under control of the generator

Compatible with contents (no acids in metal cans)

STORAGE CONTAINERS

Kept closed at all times except when in use

Properly identified with waste tags before pickup

Transported with a non-leaking screw on cap

Filled to a safe level (not beyond the bottom of the neck of the container or a 2 inch head space for 55 gallon drums)

Do NOT use red bags or sharps containers for storage

ACCUMULATION OF CHEMICAL WASTE A generator of potentially hazardous waste may

accumulate up to a total of 55 gallons of waste which may be determined to be hazardous or one quart of acutely hazardous waste

In the event more than this volume will be generated, contact Safety for a special pick-up

Hazardous waste in excess pf 55 gallons may not be stored at your site for more than 3 days

Refer to the Department of Safety Procedures for Disposal of Hazardous Waste Manual for details on which chemicals are compatible and incompatible

LABELING FOR PICKUP

Prior to pick-up a waste tag is required (refer to the Laboratory Safety Manual for details)

This should be filled out by the waste generator and attached to each container

When ready for disposal contact the Safety department.

A hazardous waste disposal request form will need to be filled out (refer to the Laboratory Safety manual)

An SDS should accompany the container

INSPECTIONS

The Safety department conducts regular safety inspections of all labs

Failure to comply may result in disciplinary action

NO CHEMICALS DISPOSED OF DOWN THE DRAIN At no time will any chemical be disposed of by pouring it

down the drain regardless of what is recommended by the SDS or manufacturer

Dental developer and fixer chemicals shall be stored in containers provided by the chemical transporter and disposed of as hazardous chemicals

DISPOSAL OF DENTAL AMALGAM Dental amalgam is a potential source of

mercury vapor

Dental amalgam waste & teeth containing amalgam will be placed in the designated containers placed in each operatory

Each container will be labeled appropriately

A designated vendor will pick up used amalgam

Lead foils will be collected in a plastic container

The container will be labeled appropriately

The container will be picked up monthly by a designated vendor.

DISPOSAL OF UNUSED MEDICATIONS

All unused, unneeded, or expired prescription drugs must be removed from their original containers and mixed with used coffee grounds, kitty litter, or other undesirable substances.

The litter or coffee grounds must be placed in impermeable containers such as zip-loc baggies and then in the trash to prevent diversion.Disposition of medications must include the medication name, strength, prescription number (if applicable along with patient's name), quantity, date of disposition, and disposing staff or students.

DISPOSAL OF UNUSED MEDICATIONS

Medications should NOT be placed into sharps containers.

Syringes containing medications should be emptied into kitty litter which will then be enclosed in zip-lock bags, and disposed of in the trash unless on the previous list.

Syringes will then be disposed of in the correct manner.

DISPOSAL OF UNUSED MEDICATIONS

The Board of Pharmacy recommends that any expired bottles (used or unused) of injectable controlled substances be sent for reverse distribution to:

Return Logistics International Corporation, 22 Artley Road, Savannah, GA 31408.

LABORATORY PROTOCOLS AND PROCEDURES

LABORATORY PROTOCOLS

You are responsible for the safety of your clinic or lab

If you do not know the chemicals properties ask for help

Proper PPE is required to include lab coats, and safety glasses when handling chemicals, biohazards, and radioisotopes

No shorts, sandals, or open toe shoes

No children or pets

Never pipette by mouth

Be aware of dangling jewelry, hair, and loose clothing

No food in designated refrigerators

Never work alone. If not avoidable let someone know where you are

LABORATORY PROTOCOLS

Wash hands frequently and always before leaving the lab

Do not wear PPE outside of the lab

Contact lenses should not be worn in lab

Work areas should be kept clean and free of unnecessary chemicals

Clean equipment after use to avoid cross contamination

Do not block emergency exits or equipment

Do not eat, drink, apply make-up or chew gum

EMERGENCY PHONE NUMBERSEmergency phone numbers should be posted near entrances to each lab, storeroom and beside every phone in the lab or clinic

Include Emergency Medical Services, The RSO, and the Office of Safety

EMERGENCY PROCEDURES

Fire-Pull the nearest fire alarm. If you are unable to control or extinguish a fire follow building evacuation plan

Accidents-attend to person who may have been contaminated if it is safe to reach them. Use safety showers and/or eye washes as appropriate. Flush eyes for a minimum of 15 minutes and seek medical attention immediately.

Ingestion of substance- call Poison Control Center at 1-800-POISON

Skin Contact-wash skin with water and remove clothing or jewelry. If symptoms persist seek medical attention.

Spill- notify persons in the immediate area. Evacuate all non-essential personnel

EMERGENCY PROCEDURES

Flammable spill- Turn off all ignition sources. Avoid breathing vapors. Be aware some chemicals have no odor or create olfactory fatigue(you stop smelling the odor quickly)

Leave on or establish all exhaust ventilation and close doors to prevent spread of the odors

Call Emergency Services1-911in case of fire, if there is immediate threat to life, or any other emergency situation

BUILDING EVACUATION

Be aware of marked exits

To activate the fire alarm, pull the handle on one of the red boxes located in the hall

In the event of a fire, call 1-911

If the fire alarm sounds, exit through the nearest exit

Proceed to designated assembly area and check in with designated personnel

Do not return to the building unless instructed by Security

Refer to the Emergency manual for detailed instructions for building evacuation and other emergencies

HAZARDOUS CHEMICALS INCIDENTS

Be aware of which products contain hazardous chemicals

Know what hazards are associated with these products

Know the proper hygiene for working with dental products

Know what to do in case of a spillKnow the location of your spill kitHave the necessary supplies on hand

SPILL RESPONSE EQUIPMENT In the event of a MINOR spill utilize the spill response

equipment. Specific contents of the spill kit may be found in the Laboratory Safety Manual.

Refer to SDS to determine cleanup method

Use appropriate PPE

Cover liquid spills with absorbent material (check compatibility)

Cover powdered materials with wet paper towels

Neutralize corrosive if appropriate materials available

Clean from the outer area towards the center

Place spilled material in impervious container, seal, and contact Safety Department for disposal

Wash/mop up area

A solvent (xylene) may be necessary to clean surfaces contaminated with a non-water soluble chemical

CHEMICAL SPILL KITSThe Spill-Kit container should include: Chemical spill instructions Utility gloves and protective eyewear Kitty litter, vermiculite or a 50.50 mixture of the two

Sodium bicarbonate (Baking soda) Plastic non-sparking scoop Plastic bags Dust pan Paper towels Fresh 1:10 bleach solution

BIOLOGICAL HAZARDS

Respond only if you have been trained…otherwise summon assistance

Attend to anyone contaminated or injured if safe to reach them

Call Emergency Services (1-911)

If room equipped with UV lights, turn them on

Evacuate non-essential personnel. Leave the lab and close doors

Remove contaminated clothing and place in impervious container, seal and label, avoid contact with others, take a shower

Put on PPE

BIOLOGICAL HAZARDS

Wait 30 minutes for aerosol to settle before entering

Turn off UV lights and check for visible mists before entering

Apply appropriate disinfectant to spill with gentle flooding action to avoid secondary aerosols

Cover excess liquid with absorbent material and dry material with wet paper towels

Place spill clean-up material into a container and autoclave or call Safety Department for disposal

Wash affected surface with strong disinfectant

FUNDAMENTALS OF LABORATORY SAFETY

FUNDAMENTALS OF LABORATORY SAFETY

Procurement

Before a substance is received information on proper handling, storage and disposal must be known. Refer to SDS

All chemicals must be properly labeled

Stockrooms/Storerooms

Chemicals must be segregated and stored properly depending on their properties

Stored chemicals should be examine periodically (at least annually)for leakage and to make sure labels are secure

Distribution

When moving chemicals place in an outside secondary container

Use freight elevators whenever possible when transporting chemicals

FUNDAMENTALS OF LABORATORY SAFETY Laboratory Chemical Storage

Read labels carefully before storing

Store according to the Chemical Storage Segregation Scheme in the Laboratory Safety Manual

Store all chemicals by their hazard class not in alphabetical order

Do not store near heat sources or in direct sunlight

Date chemicals when received and first opened

Do not use lab benches as permanent storage for chemicals

Inspect chemicals routinely

FUNDAMENTALS OF LABORATORY SAFETYDo not store chemicals in glass containers on the floor

Do not use fume hoods as permanent storage areas

Contact Safety Department for disposal of old, outdated or unused chemicals

Do not store chemicals above eye level

Do not store excessive amounts of chemicals in the lab

Store in proper storage cabinets(Refer to safety manual for specific requirements for storing in these cabinets)

• Flammable storage cabinets

• Acid storage cabinets

• Compressed gas cylinder cabinets

SIGNS AND LABELS

Laboratory inventory posters including emergency contacts must be posted outside of each work area

Labels must be placed on all chemical containers

Secondary containers must be labeled

Waste disposal tags must be used to identify waste

Employee notification posters must be current and posted-The Right To Know (can be obtained from Safety Department)

Florida Hazard Communication Act rights for employees

Lab supervisor must keep this poster up to date

Safety signs for safety equipment, first aid equipment & exits

Warning signs where special or unusual hazards exist

Food and beverage consumption and storage permit signs

SAMPLE OF POSTER & SIGNS

BASIC RULES AND PROCEDURES IN THE LABORATORY

BASIC RULES AND PROCEDURES IN THE LABORATORY Follow laboratory procedures for assembly of lab apparatus

(refer to Lab Safety Manual)

Follow laboratory procedures for use of lasers(refer to Lab Safety Manual)

Follow laboratory procedures for safe use of cooling baths and cold traps(refer to Lab Safety Manual)

Follow laboratory procedures for safe use of vacuum pumps (refer to Lab Safety Manual)

Examine electrical cords periodically

Make sure all electrical equipment is grounded

Do no run cords along the floor where they create a tripping hazard or above the ceiling

Do not plug too many cords into one outlet

FUME HOODS

Equipment and other materials should be placed at least 6 inches behind the sash

When hood not in use pull the sash all the way down

Do not keep loose paper or towels in the hood

Do not use as a storage cabinet

When using large equipment keep it raised 1.5 inches off the work surface to allow ventilation

Do not block fume hooddo not modify the fume hood

Minimize the foot traffic in front of a hood

SPECIFIC CLASSES OF HAZARDOUS CHEMICALS Reference the Laboratory Safety Manual for specific

details for working with:

Embryotoxins

Chemicals with chronic or high acute toxicity

Substances of high chronic toxicity

Flammable solvents

Oxidizers

Corrosives

Reactives

BIOSAFETY LEVELS

Refer to laboratory Safety Manual for specific details for working in the different biosafety level areas.

GAS CYLINDERS• OSHA requires that all gas cylinders be

secured to prevent tipping• Always use appropriate regulator on

cylinder• Be legibly labeled and marked to

clearly identify the department and gas• Be stored to protect against external

heat sources• Do not use oil or grease on any cylinder• Be stored as not to be damaged by

passing or falling items• Valve protectors must also be in place

when cylinder not in use • Valves must be closed if cylinder is

being moved• Inspected regularly

GAS CYLINDERS

Never use cylinder if it cannot be positively identified

Place all cylinders so the main valve is accessible

Remove regulators from all unused cylinders and place protective safety cap

Store oxygen at least 20 feet from a flammable material

Never roll a cylinder

Never drop or strike a cylinder

use designated wrenches or tools to open valve

Store compatible gases together

RECORDS AND TRAINING

RECORDS

Lab supervisor or program manager or designee will be responsible to assure that Incident Reports are filed with Security

Medical records associated with an exposure will be maintained by the facility in accordance with State and Federal regulations

If a medical consultation is performed HR will obtain a written opinion from the examining physician to include:

Follow-up recommendations

Results of the exam

Statement that the lab personnel has been informed of the results and any follow-up treatment needed

SDSs will be available in each lab for all hazardous chemicals

TRAINING Every lab worker must be trained to know the location and proper use

of PPE (refer to the Laboratory Safety manual-”Basic Rules and Procedures for Working with Chemicals”)

Training must be provided at the time of initial employment and then annually or as needed when a new chemical is introduced

Training must include at minimum:

Location of the Laboratory Safety Manual

Locations of SDSs

The permissible exposure limits (PEL) for OSHA regulated substances or the exposure limits for other chemicals where there is no OSHA standard (refer to appendix for PEL’s in Laboratory Safety manual)

Signs and symptoms of exposures

Methods to detect the presence or release of a hazardous chemical

The physical and health hazards of the chemicals in their work area

The measures lab personnel can take to protect themselves from the hazards

The applicable details of the Laboratory Safety manual

HAZCOM TRAINING

Hazard Communication training is required when the employee is hired and then annually or as needed to include:

Chemical labeling (new CHS requirements)

SDSs

Spill clean-up and chemical disposal

Chemical storage guidelines

Hazards specific to different chemical groups

Implementing new formats

TRAINING

Lab safety training must take place at the time of hire and then annually or as needed and must include:

Safety equipment and practices

Emergency procedures

Emergency equipment

Waste disposal

Fire Extinguisher training is required for all lab personnel

What to do in the event of a fire

The behavior of fires

The classes of fires and proper selection and use of a fire extinguisher

Waste Management Training and Bloodborne Pathogen Training must take place at the time of hire and then annually or as needed. (the requirements covered previously in BBP section)