The Occupational Safety and health administration (OSHA) recently revised several of its standards, including the Hazard Communication Standard (29 CFR 1910.1200). The final rule took effect May 25, representing one of the most significant changes to OSHA standards in many years. These standards will affect how health care organizations communicate to their employees, and it’s important for ASHE members to understand the changes.
OSHA says the revisions will improve safety, facilitate global harmonization of standard, and produce hundreds of millions of dollars in annual savings. OSHA also estimates the he changes will prevent 43 fatalities and 521 injuries and illnesses annually in the United States.

The new revisions align OSHA standards with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS)-a system for standardizing the classification and labeling of hazardous chemicals.

OSHA’s new rule means that some states will also be changing their rules. The 27 states and US territories with their own OSHA-approved occupational safety and health programs are required to revise their standards to match the changes represented in the OSHA standards. The state or territory standards must be at least as effective as the federal OSHA standard, and it must be implemented by September 26th, 2012.
OSHA and state based occupational safety and health agencies inspect hospitals regularly. OSHA focuses its inspection resources on the most hazardous workplaces in the following order of priority.

1. Imminent danger situations
2. Fatalities and catastrophes
3. Complaints
4. Referrals
5. Follow—Ups
6. Planned or programmed investigations

The OSHA hazard Communication Standard continues to be one of the most commonly cited standards for hospitals and nursing/personal care facilities. It was the second and fifth most commonly cited standard for hospitals and nursing/personal care facilities, respectively, during the period of October 2010 through September 2011. As hospitals implement programs to comply with the revised standards over the next few years, it’s likely that the Hazard Communication Standard will continue to be one of the most commonly cited standards.

OSHA’s final rule makes changes to multiple standards in both the General Industry and Construction regulations. Most of the changes are focused on three primary topics: labeling of hazardous chemicals, safety data sheets (formally known as “material safety data sheets”), and training. Specifically the following changes are most likely to affect health care organizations:
HAZARD COMMUNICATION STANDARD (29 CFR 1910.1200)

Much of the final rule impacts the OSHA Hazard communication Standard. OSHA edited, deleted and added several definitions for “health hazard” and physical hazard to reflect the new hazard classification specified in the GHS.

The revised Hazard Communication Standard includes two new appendices regarding classification of health hazards and physical hazards. These appendices provide detailed criteria for assigning hazard classifications. Most classifications will be performed by chemical manufacturers and distributors, so employees of health care organizations are not likely to assign hazard classifications to chemicals.

Chemical manufacturers, importers, and distributors will be required to label, tag, or mark each container of hazardous chemical with the following information:

• Product identifier: The product identifier is the product name listed on the safety data sheet.

• Signal word: Signal words include “danger” and “warning”.

• Hazard statement(s): Hazard statements are assigned to hazard classes and categories, and they describe the nature of the hazards of a chemical. Examples include “may cause respiratory irritation” and “flammable gas.”

• Pictogram(s): OSHA identifies nine pictograms that may be used as labels.

• Precautionary statement(s): There are four types of precautionary statements related to prevention, response, storage, and disposal. Appendix C of the Hazard Communication Standard provides permissible precautionary statements assigned to each hazard classification.

• Name, address, and telephone number of the chemical manufacturer, importer or other responsible party.
Health Care Employers are required to ensure that hazardous chemical containers within the workplace are labeled with the product (1) identifier and (2) words, pictures, symbols, or a combination thereof that provide general information regarding the hazards of the chemical. This requirement will affect laboratories, maintenance shops, and patient care areas that handle hazardous chemicals. If employees maintain the container labels provided by chemical distributors when handling hazardous chemicals, such labels are likely to meet the OSHA criteria.

Laboratory employers the ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor under the Hazard Communication Standard; they must ensure the hazardous chemical containers leaving the laboratory are labeled with the six elements listed above.

OSHA replaced use of the term, “material safety data sheet,” with “safety data sheet” (SDS) in all of its standards. Additionally, the Hazard Communication Standard now specifies that SDSs Contain 16 sections. The new appendix D of the Hazard Communication Standard provides detailed descriptions of the information that should be included in each SDS section.

OSHA places responsibility on the chemical manufacturer or distributor for preparing the SDSs with the required sections. However, employers (i.e., health care organizations) are responsible for providing SDSs that contain the required information for each hazardous chemical to employees in their work areas. Consequently, health care organinizations should make plans to update their SDSs to comply with the requirements.

FLAMMABLE LIQUID STANDAR (29 CFR 1910.106)
OSHA revised its Flammable Liquids Standards to align the classification of flammable liquids with the GHS. OSHA no longer uses the flammable liquid classification scheme used by the Nation Fire Protection Association (i.e., Class IA, IB, IC, II and III liquids.) Instead, flammable liquids are assigned one of four categories.
CHEMICAL-SPECIFIC STANDARDS (29 CFR 1910.1001 through 29 CFR 1910.1052)

The chemical-specific standards include those addressing asbestos, cadmium, lead, ethylene oxide, formaldehyde, and others. Most of the changes to these standards are related to warning signs and labels. For example, warning signs at entrances to asbestos regulated areas (i.e., area where airborne concentrations of asbestos may exceed permissible exposure limits) shall read:
DANGER ASBESTOS
MAY CAUSE CANER
CAUSES DAMAGE TO LUNGS
AUTHORIZED PERSONNEL ONLY.

Likewise, warning signs at entrances to formaldehyde regulated area (i.e., area where the concentration of airborne formaldehyde exceeds either the permissible exposure limit or short term exposure limit) shall read:
DANGER FORMALDEHYDE
MAY CAUSE CANCER
CAUSES SKIN, EYE, AND
RESPIRATORY IRRITATION
AUTHORIZED PERSONNEL ONLY

This new language for asbestos and formaldehyde regulated areas is slightly different from the previous standards. This new language aligns the signage with the GHS. Similar changes regarding language on warning signs are also no required in the OSHA standards for cadmium, lead, and ethylene oxide. Health care organizations should make plans to update existing warning signs to reflect the new standards.

EFFECIVE DATES
The final rule became effective on May 25. However, OSHA is not expecting employers to be fully compliant by that date. Instead, OSHA has established a set of target dates for compliance. OSHA expects employers to train employees regarding the new label elements and safety data sheet format by December 1, 2013. Workplace labels and the hazard communication program shall be updated by June 1, 2016. Other Provisions shall be updated by June 1, 2015.

The new hazard communication standards contained within the final rule represent one of the most significant changes to OSHA standards in recent years. Upon implementation of the standards, chemical hazard labels, warning signs, and safety data sheets will have consistent terminology and formats. Such consistent is likely to make it easier for employees to identify and understand the hazards associated with chemicals. Workplace safety should ultimately improve as employers implement the new standards.
-Inside ASHE , Leo T. Old 2012