Ask the expert: ASC, MSDS, and hazardous drugs
Q: Is an ambulatory surgery center required to keep an MSDS file for the medications that are used in the facility?
A: If a drug is identified as hazardous and there is potential for exposure under normal working conditions, then the Hazard Communication Standard (HCS) applies, including the requirement to have an MSDS.
OSHA’s Hazard Communication FAQ explains:
The HCS only applies to pharmaceuticals that the drug manufacturer has determined to be hazardous and that are known to be present in the workplace in such a manner that employees are exposed under normal conditions of use or in a foreseeable emergency. The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards. The employer may rely upon the hazard determination performed by the pharmaceutical manufacturer or importer.
An OSHA letter of interpretation, however, provides an important exemption:
“Drugs, as defined in the Federal Food, Drug and Cosmetic Act, in solid, final form for direct administration to the patient (i.e., tablets, pills, capsules) are exempt from coverage under Section 1910.1200(b)(6)(viii) of the HCS. MSDSs are required for all other hazardous drugs.”
This applies to all businesses, including ASCs.
If you struggle with when you need an MSDS and when you don’t, download the “Determining when an MSDS is necessary” decision chart from the Tools page.