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Organizing the MSDS

By: December 11th, 2012 Email This Post Print This Post

Q: I am trying to standardize and simplify the organization of the MSDS in our organization. Many products that we use have a constituent in them that may be hazardous. In a true emergency, the employee may not know what hazardous substance is in the product but should know to look it up in the MSDS manual. An example is laboratory test kits that may contain a diluent or extraction solution. In that case, do you organize the MSDS by the manufacturer’s brand name, or by the common name of the product? What are you suggestions/guidelines?

A: My recommendation is to organize alphabetically based on the common names, since in an emergency this is where staff members will look first for information. OSHA requires that the name on the actual container label match up with the name on the MSDS, so do a spot check of this, too. If you use an identical product from multiple manufacturers, you don’t have to file an MSDS for each company. A single representative MSDS is okay as long as the information is complete and your staff members know which product it’s for.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Who should attend safety meetings?

By: November 12th, 2012 Email This Post Print This Post

Q: I’m planning safety meetings for our staff (not yearly retraining). Are clerical employees required to attend every meeting if only medical issues are being discussed? Is a quarterly meeting okay?

A: No, clerical employees do not need to sit through meetings solely on clinical safety items. Quarterly meetings are good, but don’t overlook all the opportunities you already have at your normal staff meetings. Take a couple of minutes to talk about a safety-related topic. Timely events and examples really hit home. You’d be surprised how many poeople in your office can’t describe where to find the fire alarms or how to operate the eyewash station. Just three to five minutes at the start of the meetings really reinforces a safety-first attitude. For maximum impact, keep these mini-presentations short and to the point. You may not even need another quarterly staff safety meeting!

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Ask the expert: Safety training in a medical office

By: October 15th, 2012 Email This Post Print This Post

Q: How often does safety training (bloodborne pathogen, hazardous materials, respiratory, etc.) need to be done within a medical office?

A: Strictly speaking, the only education pieces with specific recurring frequencies are the bloodborne pathogens education and respiratory protection education, which are required to be provided prior to initial work assignment and then annually thereafter.

Also, if there’s an expectation that folks in your office would use fire extinguishers as part of the fire response plan, then there is an annual requirement for extinguisher education as well (OSHA doesn’t specify the nature of the education, so it could be hands or on by demonstration, which could include a video presentation).

Interestingly enough, there is no OSHA  requirement for annual fire drills, but if your medical office operates under the auspices of a hospital, there is an annual requirement for fire drills (and to be quite honest, it would have to be considered an excellent practice to conduct fire drills at least annually).

Other education concerns such as hazard communications and emergency response are required prior to initial work assignment and then whenever there is a change to procedures. There are a number of other potential education concerns that are promulgated as a function of General Industry; to that end, you may find the information on the following webpage ( to be of use, depending on your circumstance.

- Answered by Steve MacArthur, consultant for The Greeley Company, a division of HCPro, and author of Mac’s Safety Space.

Ask the expert: ASC, MSDS, and hazardous drugs

By: January 26th, 2012 Email This Post Print This Post

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.


Top 10 “Ask the Expert” questions for 2011

By: January 18th, 2012 Email This Post Print This Post

The “Ask the Expert” posts, which appear on this web site, in addition to being real questions posed by safety professionals in healthcare facilities, are some of the most popular features of the Medical Environment Update newsletter.

Readers tell us that the posts are also good as discussion starters for safety committee meetings or staff training session.

Here are the top ten most popular posts from 2011.

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Ask the expert: MSDS files and hazardous substance list

By: November 4th, 2011 Email This Post Print This Post

Q: If we already have a paper MSDS file, must we also have the list of hazardous substances?

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Ask the expert: Timing for new employee hazard communication training

By: October 19th, 2011 Email This Post Print This Post

Q: How soon must new employees receive training under the Hazard Communication standard?

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Ask the expert: MSDS replacement frequency

By: May 31st, 2011 Email This Post Print This Post

Q: How often must we replace MSDSs in our MSDS file?

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Ask the expert: Generic MSDS

By: January 14th, 2011 Email This Post Print This Post

Q: We changed to a different manufacturer for the purchase of isopropyl rubbing alcohol in our practice. Is it okay to use the old MSDS, or do we have to request a new one?

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Ask the expert: Squeeze bottles as emergency eyewash stations

By: January 5th, 2011 Email This Post Print This Post

Q: We are establishing a chemotherapy suite for our practice. Are the portable squeeze bottle eyewash units we already use okay for this new area?

A: Squeeze bottle emergency eyewash stations are usually not compliant because, used alone, they cannot provide the required flush time for exposures found on most MSDSs. They are mostly used as an emergency measure to get workers to a plumbed eyewash station.

Check the MSDS for the hazardous substances present in the new area, including hazardous drugs, to determine how long a flush is required for exposure to eyes and mucous membranes. That flush time is what the eyewash station is required to provide to be OSHA compliant.

Ask the expert: How long to retain old MSDSs

By: September 16th, 2010 Email This Post Print This Post

Q: How long do you have to keep MSDS files for products no longer used in the health center? I did not see that information on the Safety Recordkeeping Requirement sheet on the Tools page.

A: You don’t need to keep MSDSs for products no longer in use.

Keep in mind however that you do need to keep either the MSDS, 1910.1020(c)(5)(iii), or a “chemical inventory or any other record which reveals where and when used and the identity (e.g., chemical, common, or trade name) of a toxic substance or harmful physical agent,” 1910.1020(c)(5)(iv), according to the OSHA Access to Employee Exposure and Medical Records standard.

Ask the expert: Do you need an MSDS for Wite-Out?

By: July 16th, 2010 Email This Post Print This Post

Q: When I look at my bottle of Wite-Out®, it states that it is flammable and that people should avoid prolonged skin contact and breathing vapors. This sounds to me like an MSDS is needed.

A: Consumer products used in accordance with the label are not generally considered under the hazard communication standard. In fact, an OSHA letter of interpretation specifically addresses office chemicals saying:

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