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The E-Digest OSHA Compliance & Practice Safety Newsletter - Issue 25 – February 2007

In this issue:

* Material Safety Data Sheets (MSDSs) for drugs?
* How to Read an MSDS
* Making Sense of Hazard Labels
* Make your own Spill Kit
* Reminder to Post Accident Data

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Welcome to this issue of The E-Digest OSHA Compliance & Practice Safety Newsletter! We've added this service to our web site and it's FREE, so pass the word. The E-Digest covers a whole range of safety and OSHA compliance topics in each issue so there's something for everyone! The articles are all specific to the veterinary profession. Every couple of months you'll receive a new issue of The E-Digest Newsletter packed full of useful information and links to resources on the web that are selected specifically to enhance your hospital's safety operations!

And as always, if we can be of further assistance, don't hesitate to call on us.
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Material Safety Data Sheets (MSDSs) for drugs?

There seems to be a lot of misunderstanding about the applicability of OSHA’s Hazard Communication Standard (Title 29, Code of Federal Regulations, Section 1910.1200) to medicines and drugs. Many safety directors are confused by the “total exemption” of some products, but only the “partial exemption” of others. The good news is that OSHA has issued several directives and interpretation letters on this issue which can be found on their web site (www.osha.gov). They have been very consistent in their application and interpretation of this standard with regard to pharmaceuticals, so it makes it easier to apply the interpretation in the practice.

First, pharmaceuticals are NOT categorically exempt from this regulation. There are parts of the regulation that do not apply to them, but drugs, like all other chemicals are subject to the provisions of the HCS if they contain 1% or more of a substance considered hazardous.

Here’s a more thorough explanation of the rules regarding MSDSs for drugs:

 http://www.safetyvet.com/osha/drugmsds.htm

Check out this page on our web site to learn more about the best way to set up your MSDS library:

 http://www.safetyvet.com/osha/MSDS1.htm

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How to Read an MSDS

Having an MSDS is only part of preparing your workplace for a chemical accident or emergency.  Understanding them is another matter.  Check out this web site for some great information on how to better understand the information on an MSDS.

http://www.ilpi.com/msds/faq/index.html

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Making Sense of Hazard Labels

There is no special system that must be used; the labels can be pre- designed (store-bought) or home-made. They can use words, pictures, colors, or any other method to communicate the information. The labels don't even have to be labels! Specially color-coded bottles or even tags, ribbons or signs can be used in certain places. When deciding which method to use, consider the chemical involved, the size, and design of the container, and how it will be used.

The labels should be uniform throughout the practice; this simplicity is easier to explain in the written plan and easier for staff members to understand. It also gives the impression of consistency to the whole program. The information contained on the label must identify the chemical contents and display the appropriate hazard warnings. For instance, a bottle of alcohol would have a label that identified the contents as alcohol and warns the user that it is flammable, harmful if ingested and to avoid contact with the eyes.

Here’s some more information on understanding hazard chemical labels:

http://www.safetyvet.com/osha/labels2.htm

And if you’re looking for some veterinary-specific labels, be sure to check out ours:

http://www.safetyvet.com/library/labels.htm

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 Make your own Spill Kit

There are special pre-packaged spill kits containing commercial absorbent pads (like the ones used for oil spills) and chemical inactivators that can be purchased, but in most practices a spill kit can be made from materials already in the practice.

Here’s what should be in your spill kit:

http://www.safetyvet.com/osha/spillkit.htm

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Reminder to Post Accident Data

Practices with more than 10 staff members (employees) are reminded that a summary of workplace injuries and illnesses that occurred last year (2006) must be posted for three months (February 1 through April 30). The summary (OSHA Form 300A) must list the total number of job-related injuries and illnesses that occurred in 2004 and were logged on the OSHA 300 form (Log of Work-Related Injuries and Illnesses). When required, this form must be displayed in a common area where notices to workers are normally posted. The annual requirement is part of OSHA's recordkeeping regulations.

To read more about OSHA’s recordkeeping rules and how they apply to the veterinary practice, visit this web page:

http://www.safetyvet.com/osha/recordkeeping.htm

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Have Fun & Be Safe :-)

Philip Seibert, CVT