I’ve been getting a lot of customer e-mail lately about the new OSHA GHS requirements, and what constitutes “compliance.”
Like good boys and girls, you the safety folks have been doing the right thing, it seems, by making sure your employees are trained and calling the manufacturers of the nasty chemicals in your facility to try to get your updated SDS sheets, like OSHA wants you to.
The problem lies in some manufacturers, who either haven’t gotten the memo, or just are not as diligent.
Confusing? Frustrating? We know, and so does OSHA.
I just sat through a session at the American Society of Healthcare Engineers (ASHE) conference about this and listened to some SDS experts try to explain this. The bottom line is that yes, manufacturers were technically supposed to be working with the new labels as of June 1. However, OSHA decided to give them a transitional period until December 1 to ship and distribute any old inventory with the old labels.
The problem is this … even if you have a manufacturer of “Methyl-Ethyl Kill You Now” who is complying with the new OSHA GHS, there may be an ingredient in that whose manufacturer has not complied yet. So that holds everybody up. Hence the grace period.
So what does this mean for you, and for clinics?
Basically, you need to show that you are in compliance and that you are doing the best you can. At this point, and up until June 2016, as long as workplaces have an MSDS or an SDS for every chemical they stock, they are considered in compliance. That’s why employees need to be trained on both systems.
As for manufacturers, they don’t yet have their act together. So the workplaces need to do their diligence, and to do something. They cannot sit on their duffs and wait for the manufacturer to send the SDS. They need to be able to show an inspector that they are trying something. Document phone calls, emails, keep a folder with any correspondence, etc. As long as they are making a good faith effort, OSHA will be OK with it.
After June 2016, though, all bets are off. Everyone must comply with the new system.
Hi folks –
By now you know that I often ask you for your opinion and expertise to help me write stories for our safety newsletters, Briefings on Hospital Safety and Medical Environment Update. Now, I’d like to ask you to help me make your job easier to do.
For some time, we have been working on building a new Web portal that will be designed around your needs as a safety professional. The goal is to develop a place where you can go every single day to get all of the information and tools you need to keep up with what the regulators are doing, help keep your facility in compliance, and to make your workplace a safer one.
During the month of August, I will be conducting a series of focus groups, and I want as many of you as possible to participate. This will be your chance to tell me what you want in an online web portal. I want to know where you are now getting your information, if not us, and why?
Do you want more tools, checklists, and forms? More news and analysis? A way to connect with your peers? And how do you want that information? Do you like things you can print out, or do you want to view it on a tablet?
All of this information will help us design a better web experience around you, the user. Some of you may be familiar with our current online presence at www.hospitalsafetycenter.com. Please take a good look and let us know what we are doing right, and what is lacking or what needs updating, and what we can do to make it better.
Also, please let me know your availability and we will design these one-hour focus groups around your schedule. My goal is to get as much information as we can by September so we can get started on building our future portal for you.
Feel free to reach out to me at email@example.com.
As always, I thank you for your time, as I know you are very busy. I look forward to hearing from you soon.
Managing Editor, Safety
We get a lot of emails from customers confused about an OSHA standard or another issue related to healthcare safety. I will attempt to answer these questions myself, or ask one of our industry experts to give us a helping hand. From time to time, I’ll share some of these questions that I think will help you out in your job. Feel free to reach out to me at firstname.lastname@example.org.
“I do the OSHA training for eight large ophthalmology clinics in the greater Kansas City area. We do not really run into a lot of blood and such. We do some minor procedures in the office, such as injections, angiograms, and biopsies, but have three surgery centers where we do most surgical procedures.
First, is it mandatory for a medical clinic such as ours to have a hazardous spill kit on site? And next, Our cleaning company uses “green” chemicals to clean our office. I am of the old school that bleach, Lysol and things like Cavaside, etc. are proven germicides and disinfection products. Are these “green” chemicals as efficient? What does OSHA say about these “green” chemicals? Last, we store some old paint cans in the back room, just in case we need to get matching paint in the future. Do I need MSDS/SDS on these too?”
It depends what you mean by “mandatory.” As in, it’s the law and you can be arrested? Of course not. And I don’t think there’s any kind of mandate on the books for either in any of the standards. I also believe it depends what kind of nasty stuff you are dealing with on a daily basis. The mandate lies in the Hazard Communication standard, which states that you must have an SDS on site for any chemicals you use, even simple household bleach, because that information can help keep your workers safe.
You can bet an inspector would be on you if you couldn’t prove you could contain a bad spill, especially if there’s a chance it could go down the drains and pollute the sewers. Then they can get you for the General Duty Clause. Then you’re dealing with EPA and health departments and everything else. I would say, yes, be on the safe side and get a kit. You will look good, and will CYA should there be an issue.
As for the next questions, again, I think it depends on your definition of “green,” and what it is in the cleaners. I too, am of the same old school that says let’s just use bleach. OSHA, on the other hand, couldn’t really care if the cleaners are green. They are concerned with whether there is stuff in it that could harm you, me, your workers, and the environment. If it’s a chemical other than good ol H2O, you need to have an SDS on site for it, train your workers on it, and make sure you have the right first aid stuff to deal with a spill and/or exposure.
And yes, definitely get SDS for the paint, just like construction companies would need to. They contain chemicals, and are flammable. Also, the the fire department and other responding agencies would need to know what is in your facility in case there is a fire.
As part of our celebration of you, the safety professional, we asked readers to let us know what the greatest challenge was in their job as a safety professional, or to share funny or insightful stories about their best or worst day on the job. We got some interesting replies; read about some of them here.
Can’t a girl just get a straight answer?
“I was asked a question regarding outdates of absorbents on the shelf. Since they are seldom used, the containers last for years. Being a diligent safety officer, I know an answer is somewhere to be found. I saw the phone number of the manufacturing company, called it and was mystified by the message. I must have copied the number incorrectly, so I rechecked and redialed with the same message appearing. (It was referencing to another 800 number for a ‘WILD DATE NIGHT’).
I certainly couldn’t let it go at that, so continued my saga of the outdate mystery. I discovered this product was being sold and distributed by a different company, and was marketed as a disinfectant. Since it was an absorbent/deodorant and not a disinfectant, the company was sued $277,953 by the EPA and had to perform two environmental projects costing at least $107,000. The company had to distribute its remaining inventory and is no longer producing more of it. I called that company and found out ‘there is no outdate, just use it ‘til it’s gone.’
I never called the hot date line!”
– Linda Gylland, MLS (ASCP) QLS, lab safety officer for Sanford Health in Fargo, North Dakota.
A leg up on waste removal
“We are one of the remaining few hospitals in the southeast that still has an autoclave, shredder, and trash compactor on site for our bio-hazardous trash. We were in the process of feeding all of the biohazard waste over to a national company and halted the process when the Ebola outbreak was occurring.
Several years ago, we had another contracted company with environmental services. They conducted most of their education classes by video. So, you really did not know what the new employee got out of the education. We had hired several new guys to run the trash line. I guess they never really imagined ALL the types of things we put in the trash at a hospital.
One of the big, burly guys was working real hard to empty his cart from the first floor soiled utility closet. This closet was the drop-off for surgery and the delivery suites. He was throwing bag after bag into the shredder. He had overloaded it and the machine pulled the bags through but it kicked out a LEG.
The guy had no idea where or what that was about. He screamed all the way from the dock area, through the tunnel to the hospital, through the connection hall, to the EVS (environmental services) office.
‘A leg, a leg, a leg!’ is all he could say over and over. He thought somebody was trying to hide a body in the garbage. He had no idea what was in the trash of a hospital. It took several people to explain it to him but everybody was laughing because he was so scared.”
-Andrea Laird RN, MSN, CIC, infection preventionist practitioner for a 260-bed rural hospital in the southeast U.S.
A colorful, tasty way to celebrate safety
“Our safety committee has gone through some significant changes to become a robust, and more proactive committee. When I took over as the chair, the committee was primarily focusing only upon employee safety concerns as related to (worker’s compensation).
We now encompass three major areas of safety: patient, environmental, and employee. We have built a dashboard and set up a schedule of presentations each month to report, discuss and intervene as appropriate. We are reviewing and approving all organizational policies that relate to safety issues.
For this year’s Safety Week, the committee undertook a complete revision of our Emergency Code book, and we redid our eight emergency codes instruction sheets implementing situation action sheets (SAS) for each code, for each shift, and for our off-site offices as well as our campus entities.
Our committee members took the training out to each and every department of the organization (on and off campus), teaching to different codes each day of the week.
We involved sponsors, and were able to “reward” our attendees with a Lindt truffle wrapped in the color wrapper of each color code instructed each day. (i.e. blue wrapped truffles for ‘Code Blue,’ black for ‘Code Black,’ orange for ‘Code Orange,’ red for ‘Code Red,’ etc.)
It was a huge hit!
Employees were seeking us out when they missed a training, and are still talking about this year’s Safety Week.
We will have to find something extraordinary to do for next year’s Safety Week after the very positive response this year.”
– Nancy T. Wiggin, RN, M.Ed., C.P.P.S., NHA, Huggins Hospital, Wolfeboro, New Hampshire
Hi folks –
In case, you missed it, this weekend kicks off the annual conference of the American Society of Healthcare Engineers (ASHE), which will be held in Boston this year.
I’m looking forward to learning everything new about what keeps healthcare facilities running and safe on a daily basis.
Since that’s right in our backyard, I’ll be at the sessions, stopping at the exhibition booths, and mingling with conference attendees next week to come up with ideas for stories and new products. I hope to see you there!
If you see me, say hello, or drop me a line if you’d like to meet up and chat for a bit at email@example.com.