Safety Data Sheets Linked to Improved Workplaces
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Safety Data Sheets Linked to Improved Workplaces
By Mark Harris
C
hemicals are everywhere. They well-being. However, a crucial caveat goes sterilize work surfaces, medical supplies,
occur as part of nature and make along with the ascribed benefits of chemi- and medical instruments. Other exposure
up both living and inanimate mat- cal products: they must be used safely and risks include laboratory chemicals, pesti-
ter. Chemicals are also manufactured and appropriately to avoid harming people or cides, aerosolized medications, anesthetic
found in many commercial and industrial the environment. The significance of safety gases, fixatives used for tissue specimens,
products. A modern global inventory lists is especially relevant with chemicals catego- surgical smoke from lasers and electro-
more than 350,000 chemicals and mixtures rized as potentially hazardous to human surgical instruments, medical waste, and
of chemicals registered for commercial use health. other sources. Even pharmaceuticals used
and production.1
Most health care facilities use hazard- in cancer therapy, antiviral drugs, hormone
Manufactured chemicals can broadly
ous chemicals, which often can be found agents, and bioengineered drugs can contain
improve our quality of life, health, and
in products used to clean, disinfect, and hazardous chemicals.2
©2023 American Association of Medical Assistants CMA Today | MarApr 2023 13 safety data sheets
About 8 million U.S. health care per- tion program was
sonnel face potential exposure to hazard- designed to pro-
ous workplace chemicals, according to the tect workers from “I would post the OSHA pictograms on a bulletin board
National Institute for Occupational Safety hazardous chemi- so that employees can see them and reidentify the
and Health.3 These employees can include cals in their work- health and physical hazards. When doing safety rounds,
physicians, nurses, medical assistants, oper- place,” says Marge I would also suggest having the employee in the area
show you a container of a hazardous chemical and
ating room personnel, environmental ser- McFarlane, PhD, identify the pictograms on the label. I often find that
vices staff, laboratory personnel, and others. MS, MT(ASCP), this information needs to be regularly reinforced.”
Public awareness of hazardous chem- principal of Superior —Marge McFarlane, PhD, MS, MT(ASCP)
icals’ environmental and chemical risks Performance
continues to grow. Many federal, state, and Consultants LLC
industry protections prevent or minimize i n L a Poi nt e ,
potential chemical hazards. These protec- Wisconsin. “The
tions include safety engineering prac- program has three Nations Globally Harmonized System of
tices, regulatory and administrative key elements: a chemical inventory list, Classification and Labeling of Chemicals
rules, guidelines on the use of safety data sheets (SDSs) for each hazard- (GHS). The revised format provides more
protective equipment, and ous chemical, and a training program. A consistent and agreed-upon industry criteria
other measures. complete and accurate inventory sets up the for classifying and communicating essential
Despite efforts requirements for which safety data sheets information on hazardous chemicals. The
to prevent work- are required and what training is needed.” new format has been required of all users
place exposures, The chemical inventory should include as of June 1, 2015.6
potential a list of all on-site hazardous chemicals. “The [HCS] gave employees the right
health risks Employers should use the product identifiers to know about hazardous substances in the
to prepare the inventory, according to OSHA. workplace,” says Rachel Housman, CSP,
The identifier can be the product name, a CIH, a safety consultant and industrial
remain. common name, or the chemical name. The hygienist with Ally Safety, a Vancouver,
Those risks product identifier must be the same name Washington–based producer of workplace
can vary greatly; used on the SDS and label. Doing so will safety training videos. “Before the standard
exposure to haz- make tracking the status of each SDS was implemented in the 1980s, people didn’t
ardous chemicals in or label easier.4 have the right to know [whether] they were
the workplace can cause In turn, the SDS provides working with toxic, carcinogenic, or dan-
various acute and chronic essential information gerous products. The GHS improved the
health effects, such as skin rashes, about the properties of communication structure in many areas. It’s
adverse reproductive outcomes, cer- each chemical and known as the right-to-comprehend portion
tain types of cancer, and other health its associated phys- because it made hazardous chemical com-
conditions.3 ical, health, munication more straightforward. ... [The
and GHS] also required that [SDSs] be organized
Up to Standard into 16 simple sections, so there’s no need
The Occupational Safety and Health envi- to search for the information you need in a
Administration’s (OSHA) Hazard ronmental 10-page document—[it will] be in the same
Communication Standard (HCS) guides health haz- short section every time now.”
the management of hazardous chemicals in ards. The SDS
the workplace.4 It provides an overall frame- also contains infor-
mation about protec-
By the Book
work for government and industry efforts The 16-section SDS format orga-
to ensure chemical safety in the workplace. tive measures and safety
nizes information based on
Notably, the HCS mandates that employers precautions for handling, stor-
the following categories5:
maintain a written hazard communication ing, and transporting hazardous
program to ensure employee safety and chemicals.5 • Section 1:
protection. Notably, OSHA revised the SDS Identification
“The OSHA hazard communica- format in 2012 to align with the United
14 MarApr 2023 | CMA Today• Section 2: Hazard(s) Section 8 describes exposure controls and The Danger Zone
Identification required personal protective equipment In case of an emergency or urgent situation,
• Section 3: Composition and (PPE), while section 9 describes the chemi- quick access to the SDS file is critical, accord-
Information on Ingredients cal and physical properties. Additionally, ing to experts. “[SDSs] must be immediately
section 11 provides toxicology information. available to all staff without the need to get
• Section 4: First Aid Measures
Finally, section 16 can indicate the date a key or a computer log-in from someone
• Section 5: Firefighting Measures the SDS was created or the last revision to else,” notes Dr. McFarlane. While most medi-
• Section 6: Accidental Release the SDS and where any changes or updates cal practices today maintain many records
Measures were made.5 electronically, a backup SDS file should be
Overall, OSHA’s GHS update, which available in case of a power outage or other
• Section 7: Handling and Storage
aligns U.S. standards with international clas- emergency that prevents timely access to the
• Section 8: Exposure Controls and sification and labeling criteria, has several electronic record system. Keeping a hard
Personal Protection advantages, explains Dr. McFarlane: copy folder or binder of the file accessible
• Section 9: Physical and Chemical can help in such circumstances.
• Reduced confusion about hazard
Properties “For instance, if a medical practice
classifications
operates on multiple floors, my recom-
• Section 10: Stability and Reactivity • Increased understanding of recom- mendation is to always have a binder of
• Section 11: Toxicological Information mended safety precautions, approved your [SDSs] on each floor [and] available
• Section 12: Ecological Information use, proper storage, and disposal of electronically so that anyone can access it
(Nonmandatory) chemicals and mixtures from anywhere,” advises David J. Zetter,
PHR, SHRM-CP, CHCC, president and
• Section 13: Disposal Considerations • Better downstream risk management
lead consultant at Zetter Healthcare in
(Nonmandatory) by increasing the understanding of
Mechanicsburg, Pennsylvania. “That way,
hazardous chemicals’ risks
• Section 14: Transport Information [the SDS] is easily accessible, and all staff
(Nonmandatory) • Facilitated training with uniform should [know its location].”
SDSs and well-defined hazard classes The issue of quick access to SDSs is a
• Section 15: Regulatory Information
(Nonmandatory) • Enhanced worker understanding safety issue, adds Viviane Potucek, CMA
(AAMA), a practice manager for an ortho-
• Section 16: Other Information • Improved worker safety
pedic medical practice at the Hospital for
Several sections of the SDS could be • Enhanced international trade Special Surgery in Stamford, Connecticut.
considered particularly essential for “For medical assistants and [practice] staff
health care providers, according to Dr.
McFarlane, who is also a safety engineer-
ing and environmental public health
expert. For example, section 1 identi-
fies the chemical name and the name,
address, and phone number—includ-
Stay One Step Ahead
ing the emergency phone number—of
Employers can implement an effective hazard communication program by following these
the manufacturer, importer, or another
six steps4:
responsible party. Meanwhile, section
2 describes the hazards and warning 1. Learn the OSHA Hazard Communication Standard and identify the responsible staff
statements associated with the chemical, member(s).
including pictograms. Section 3 describes 2. Prepare and implement a written hazard communication program.
the chemical ingredients, while section
4 covers appropriate first aid measures. 3. Confirm that containers are labeled.
In turn, section 6 gives recommen- 4. Keep safety data sheets up to date.
dations on the appropriate response to
spills, leaks, or other accidental releases, 5. Provide employee training and education.
including containment and cleanup prac- 6. Evaluate and reassess your program.
tices to prevent or minimize exposures.
CMA Today | MarApr 2023 15 safety data sheets
generally, it’s important to know what to do as the product identifier, supplier identifier, Out of Harm's Way
in case of an accidental hazards exposure or and precautionary statements. Precautionary As an experienced practice manager, Potucek
contact,” she says. “For example, if a hazard- statements include any of the following6: wants medical assistants to understand that
ous chemical gets in your eyes or you touch chemical hazards exist in many common
• Hazard pictograms
or inhale it, do you know what to do? How office products. “For instance, in our [prac-
do you clean? Do you need a specific soap? • Signal words (e.g., danger or warn- tice], we take sutures and staples out,” she
Do you use water? It’s very important to ing) notes. “Nowadays, most of the instruments
know how to respond.” • Hazard statements (e.g., “Highly we use are disposable or single use, but
For this reason, the SDS can be the go-to some [practices] might still use autoclaves
flammable liquid and vapor. May
source for urgent or timely safety informa- for sterilization. [This process] requires
cause liver and kidney damage.”)
tion. “Generally, every hazardous chemical using a disinfectant like MetriCide to clean
product in the [practice] that is used in the The necessary identifier information should the instruments before using the autoclave.
clinical area, including medications, will include the chemical manufacturer or other There are also chemical products used to
have [an SDS],” explains Potucek. “Every responsible party’s name, address, and tele- clean spills. These cleaning substances typi-
employee who is going to potentially touch phone number.6 cally have health hazards. They can be car-
or use the product in any way—either to cinogenic or have respiratory, aspiration,
An addendum might be offered on
prep somebody, for cleaning, or whatever and organ toxicity effects. That’s why you
the SDS requirements. Some common
the use may be—should be trained and may need to wear gloves or use scoops to
household consumer products—such as
familiar with it. You need to know how to scrape something off the floor.”
glass cleaner, for example—may not always
use the product [and] what can happen Other risks can be associated with
require an SDS if their use in the workplace
if an accident or exposure [occurs]. How chemical products as well, adds Potucek.
hazardous is this product? If, for example, is similar to home consumer use. However, if
“Some cleaning products can also be flam-
the product involves a substance that could the duration and frequency of a product’s use
mable, self-heating, or self-reactive,” she
potentially spill, you will need to know how in the workplace exceed typical consumer
notes. “Or certain chemicals may react with
to immediately respond.” use, staff have the right to know whether
a substance, and it becomes either hard or
Every hazardous chemical product must there might be any potential hazards associ- gelatinous. All this information will be in the
also be properly labeled based on OSHA ated with these practices. The practice may [SDS]. Even something like Clorox bleach
rules. The label should include key informa- be obligated to provide the appropriate SDS has [an SDS]. Whenever you’re training
tion such in such instances.7 someone on how to clean the instruments or
use an autoclave, how to use the appropriate
[SDS] should also be part of the training
Pictograms and Hazards process.”
HCS Pictograms and Hazards
The following images are examples of common pictograms Staff training and education on haz-
in OSHA Hazard Communication Standards10:
ardous chemical safety should occur
Health Hazard Flame Exclamation Mark whenever new hazards are introduced,
• Carcinogen
Carincogen • Flammables • Irritant (Skin and eye)
(skin and Eye) and new hires should receive training
• Mutagenicity • Pyrophorics • Skin Sensitizer
• Reproductive Toxicity • Self-Heating • Acute Toxicity (Harmful)
(harmful) before they begin work duties, according
• Respiratory Sensitizer • Emits Flammable Gas •
• Target Organ Toxicity • Self-Reactives • Respiratory Tract Irritant to OSHA.4 The training should ensure
• Aspiration Toxicity • Organic Peroxides • Hazardous to Ozone
Layer (Nonmandatory)
(Non-Mandatory) staff is familiar with the proper use of
Gas Cylinder Corrosion Exploding Bomb SDSs and hazardous chemical labels.
• Gases Under Pressure • Skin Corrosion/Burns • Explosives
Safety training should strive to pres-
• Eye Damage
• Corrosive to Metals
• Self-Reactives
• Organic Peroxides ent information in an accessible and
clear format. “The standard that gave
workers the right to know now gives
Flame Over Circle Environment Skull and Crossbones them the right to understand,” states the
• Oxidizers
(Nonmandatory)
(Non-Mandatory)
• Aquatic Toxicity • Acute Toxicity
OSHA website regarding updated HCS
(Fatal or toxic)
(fatal or Toxic) requirements.8
For this reason, periodic OSHA
safety training can serve as a refresher
course on safety practices and help to
16 MarApr 2023 | CMA Todayyou haven’t done it.” that you have to do.”
If the practice cannot locate an SDS,
“There are two important takeaways on safety data they should contact OSHA for assistance.
sheets: they need to be readily available for employees,
On Good
If necessary, employers can use the OSHA
and they need to be reviewed. The good news is these Authority
Occupational Chemical database to obtain
aren’t the tedious, jargon-filled safety data sheets of Medical practices
the ’90s. They have been updated to 16 easy-to-read information.7
should have a des-
sections. Simply find the section with the information One helpful idea is to create checklists
ignated safety com-
that you want, like first-aid measures, and review it. for some practice safety responsibilities,
Most sections are short and simple.” pliance officer or
such as ensuring the SDS folder is up
other assigned staff
—Rachel Housman, CSP, CIH to date, suggests Potucek. “You can
member who can
create a binder of checklists
oversee these activi-
for when things expire
ties to ensure adher-
or when to look for
prevent complacency about these practices, ence to OSHA safety requirements. The
updates,” she
explains Dr. McFarlane. “Employees need designated staff person can organize and
says. “You
training on the hazards of the chemicals maintain the SDS folder. Depending on
can check
in the workplace before they are exposed practice resources, an outside contractor
online
to them,” she remarks. “For example, they or consulting service can also manage this
need to know that isopropyl alcohol, which responsibility.
quar-
is commonly used in medical [practices], Fortunately, locating a product’s SDS
terly, every
is flammable and a serious eye irritant is not difficult. “Every manufacturer
six months,
[and need to be able to identify] signs and of every product with hazardous
or once a year. Has
symptoms of overexposure. Staff may not chemicals is required to pro-
anything changed or
remember or recognize the hazards because vide the [SDS] at no cost,”
need to be updated? Because
they have used this product without adverse reports Zetter, who’s also a
there are no reminders. The
effects for many years. The training program former president of the
manufacturers [will not] send us
also requires information on how to use National Society
an email [saying] the SDS for a prod-
required PPE, spill kits, first aid, and safe of C e r t i f i e d
uct has changed. We need to be proactive
segregation and storage.” Healthcare
about [maintaining current information]
OSHA safety training should be able to Business
and create systems that will help us to stay
answer most questions and concerns staff
up to date.”
members have about managing hazardous
While federal OSHA requirements
chemical risks in their workplace. “The
for hazardous chemicals apply in all states,
training and education program should Consultants.
certain states may require additional safety
communicate all the necessary safety “Fortunately, the
rules and guidelines.9 “OSHA requirements
information on the hazardous chem- [SDSs] should be
can be different in each state, depending on
icals you have on-site and where easy to find. You can
whether a state has OSHA regulations that
this information is located,” do a Google search for the
supersede federal OSHA,” explains Zetter.
says Zetter. “To [com- manufacturer and the product
“In some states, the OSHA program can
ply], the doctors have SDS. It’s almost impossible not to
be more stringent or strict than the federal
to do the train- find it.”
program.”
ing along with Potucek agrees. “In my experience,
staff. OSHA you can usually find the SDS you’re looking
train- for,” she remarks. “If you’re using Google, I Safety in Numbers
ing is for would make sure that the [SDS] information Staff should take the responsibility of work-
e ver y- is specific to the chemical—i.e., lot number place safety seriously. Regarding hazardous
one in the and registration number. You can also reach chemicals, diligence is the key to creating
practice. The out to the [chemical] vendor to get the offi- an effective, safety-focused practice culture.
practice can be cial SDS that goes with that product. If you As such, managers must try to make
fined and penalized don’t have the appropriate SDS, then you’re safety training on hazardous chemicals
if the agency finds out not being compliant, so this is something engaging and effective for staff. A large
CMA Today | MarApr 2023 17 safety data sheets
part of this challenge can involve helping ity in an already full schedule,” concludes https://www.cdc.gov/niosh/topics/hazdrug/default
.html
staff recognize their role and responsibility Dr. McFarlane. “Everyone wants to leave at
4. Occupational Safety and Health Administration.
in bolstering safe workplace practices. the end of the day as healthy as when they Steps to an Effective Hazard Communication
In other words, safety responsibilities arrived. New employees may not always Program for Employers That Use Hazardous
Chemicals. March 2014. Accessed February 15,
are not solely the safety compliance officer’s recognize their risk when using hazardous 2023. https://www.osha.gov/sites/default/files/publi
job but also require the active engagement chemicals. Over time, workers may become cations/OSHA3696.pdf
and cooperation of everyone in the practice. accustomed to the hazards, and since noth- 5. Occupational Safety and Health Administration.
Hazard Communication Standard: Safety Data
Practice managers must recognize that ing bad has happened, they often believe Sheets. February 2012. Accessed February 15, 2023.
safety education is most effective when staff nothing bad will happen. … Sooner or later, https://www.osha.gov/sites/default/files/public
ations/OSHA3514.pdf
feels personally invested in its goals, notes there may be an adverse event. Successful
6. Occupational Safety and Health Administration.
Housman, who is also a certified safety safety-based cultures require that manage- Hazard Communication Standard: Labels and
professional and industrial hygienist. “We ment and employees are engaged. Employees Pictograms. February 2013. Accessed February 15,
2023. https://www.osha.gov/sites/default/files/publi
are becoming more aware of hazardous need to be able to speak up if there are safety cations/OSHA3636.pdf
chemicals—from what’s in our food to prod- concerns. Safety policies need to be consis- 7. First Healthcare Compliance Staff. SOS for the SDS!
ucts we use at home and even in cosmetics,” tently enforced [for] every person, every First Healthcare Compliance. September 7, 2016.
Accessed February 15, 2023. https://1sthcc.com
she observes. “However, [the workplace is] task, every day. No shortcuts.” /sos-for-the-sds
one of the most important places to prevent This is certainly sound advice. Every 8. Hazard communication. Occupational Safety and
exposure. Often, our actions can make a huge staff member must be on board with OSHA Health Administration. Accessed February 15,
2023. https://www.osha.gov/hazcom/
difference in our exposures. Think of things safety requirements to avoid complacency
9. State plans. Occupational Safety and Health
like using proper PPE, following procedures, about safety-related job responsibilities and Administration. Accessed February 15, 2023.
and using fans or ventilation—all of these to work together to ensure hazardous chemi- https://www.osha.gov/stateplans/
can [greatly] impact our exposure levels. cals are managed according to the highest 10. Occupational Safety and Health Administration.
Hazard Communication Standard Pictogram.
It’s all about making the topic relatable and professional standards. ✦ 2016. Accessed February 15, 2023. https://
pointing out the ways that employees have www.osha.gov/sites/default/files/publications
/OSHA3491QuickCardPictogram.pdf
an impact on protecting their own safety
References
and health.” 1. Pelley J. Number of chemicals in commerce
With staffing shortages impacting has been vastly underestimated. Chemical &
Engineering News. February 12, 2020. Accessed
many health care services, busy staff can February 15, 2023. https://cen.acs.org/policy/chem
sometimes relegate safety practices a lesser ical-regulation/Number-chemicals-commerce
-vastly-underestimated/98/i7
tier of responsibilities. This mistake can be
2. Health care workers: chemical hazards. Centers for
dangerous. Disease Control and Prevention. Reviewed January
“We can all agree that workplace safety 13, 2017. Accessed February 15, 2023. https://www
.cdc.gov/niosh/topics/healthcare/chemical.html
is important, but most of the time, it feels
3. Hazardous drug exposures in healthcare. Centers
like an additional task competing for prior- for Disease Control and Prevention. Reviewed
May 4, 2020. Accessed February 15, 2023.
“The original Hazard Communication Standard was developed so
that workers had a right to know about hazardous chemicals in their
workplace. The [United Nations Globally Harmonized System of
Classification and Labeling of Chemicals] update is focused on workers’
right to better understand chemical hazards in their workplace. This is
accomplished using an updated, consistent format for the safety data
sheets. The 16 sections in the [safety data sheets] are now always in
a specific order. This is a key benefit. Previously, material safety data
sheets could have information in any order, and some information was
not included.”
—Marge McFarlane, PhD, MS, MT(ASCP)
18 MarApr 2023 | CMA TodayCMA Today | MarApr 2023 19
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