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Ask the expert: A hazardous substance list for your practice
Q: Must a medical practice create a list of all hazardous substances used in the workplace? It seems as if the MSDS file already covers that information.
A: Yes, the Hazard Communication standard does require the employer to compile a list of hazardous substances in the workplace as part of the written plan:
Ask the expert: Hazardous drug MSDS file
Q: For my material safety data sheet (MSDS) files, I separate chemicals from the injectable hazardous drugs. Is this OK with OSHA?
Ask the expert: Unlabeled containers and immediate use
Q: Please state the regulation allowing the removal of a chemical/medication from it’s original container and placing it into another “unmarked” container for a “small” amount of time and then using it. What defines a “small” amount of time?
A: First of all the OSHA regulation you allude to is only for hazardous chemicals. I know of none for unlabeled medications, as would be expected.
Ask the expert: Computer or paper for your MSDS?
Q: Is it okay to have material safety data sheet (MSDS) computer files instead of paper files?
A: If employees can obtain MSDS information while in the work area, computer MSDS files meet the accessibility requirements, according to an OSHA fact sheet concerning the hazard communication standard.
Ask the expert: MSDS information by telephone
Q: Is receiving material safety data sheet (MSDS) information by telephone an adequate backup for an electronic MSDS system?
Ask the expert—PDR in place of MSDS file
Q: Instead of keeping an MSDS (Material Safety Data Sheets) file for our pharmaceuticals, couldn’t we just use the PDR (Physicians Desk Reference).
A: Replacing MSDS file with the PDR would make for a non-compliant alphabet soup for your hazardous drug policy, says OSHA.
Ask the expert—Electronic MSDS systems
Q: Is putting our material safety data sheet (MSDS) binder online in compliance with OSHA?
Ask the expert: Hazardous substances in unmarked containers
Q: Our office decontaminates used instruments overnight in an unmarked basin. Is this an OSHA violation?
Ask the expert—May I get rid of material safety data sheets for household products?
Q: To clean out my files, may I eliminate material safety data sheets (MSDS) for household products such as soaps and cleaners without incurring an OSHA violation?
A: You can do without MSDS for consumer products commonly used in the workplace if employees use the products according to the label.
Ask the expert—Spill response
Q: What is the standard volume for “large” and “small” spills?
A: Sometimes the rule of thumb on this question is that you can consider anything 1 gal or less a small spill, and everything above 1 gal a large spill. However, depending on what materials are in question, you might need to make adjustments.
Ask the expert—MSDS for household products
Q: Must my practice have material safety data sheets (MSDS) for household products used in the workplace?
A: This is a common question; the classic examples being glass cleaners such as Windex and correction fluid such as Wite-Out.
Ask the expert—Written plan
Q: Must a medical practice have a written hazard communication plan?
A: If hazardous chemicals are present in the workplace, OSHA requires a written hazard communication plan. The plan must include:
