July 08, 2009 | | Comments 3
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Be wary of MSDS exemption for consumer cleaning products

My colleagues and I had a discussion recently about an OSHA reference for when material safety data sheets (MSDS) are not required when staff members use everyday consumer cleaning products.

This comes from OSHA’s hazard communications standard (1910.1200), in which section b(6) lists various exemptions from the standard, including this:

Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

That said, this passage above is not quite the “get out of jail free” card that it may first appear, as evidenced by this interpretation letter from OSHA.

The use of consumer cleaning products is a very slippery slope when it comes to its practical application in healthcare because nobody uses this stuff at work as infrequently as they do at home. Let’s use Windex as an example. You might spot-clean something at home with Windex, but you’re not likely to use it on a daily basis to the extent one might at work, which increases the range of exposures.

My practice has always been to have the MSDS available, regardless of the product. While my approach may not take full advantage of all the possible exemptions, it’s not particualrly onerous to do, so why take the risk?

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Filed Under: OSHA


Steve MacArthur About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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  1. As a Hazardous Materials & Safety Officer at an 855-bed hospital, I can tell you that, based on my experience, Steve is exactly correct when he stated that you should have the MSDS of household products even if it may be exempt from the OSHA standard. I have experienced numerous examples of patients (not in a Behavior Science unit) who have misused products, e.g. during suicide attempts. Sometimes staff even mix the products together, causing hazardous materials to be generated. Without the MSDS, you don’t know what you’re working with or what has been produced.

  2. If we have doors to staff offices and staff kitchen that have an auto-closure device, but are not ‘fire doors’, is it allowed to prop them open with a wedge?

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  1. From Beth coker | Ldorvdoronline on Feb 2, 2012

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