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What is involved in setting up a hazard chemical
program for the hospital?
your practice is inspected by OSHA, you can be sure they will want to evaluate
the effectiveness of your Hazard Communication Program and they'll certainly
begin with a review of the required plan. This plan is the hospitalís rules,
policies and procedures to ensure that employees remain safe when they have to
handle potentially hazardous materials. This plan must be written or it will not
Since you will likely have more than one written plan for the safety programs in
your hospital, itís wise to have them organized into a Hospital Safety Manual.
This is nothing more than a three-ring binder (or similar holder) that contains
copies of all correspondence directed to the staff from the leadership of the
hospital. Some practices make this an integral part of their Personnel Policy
Manual and thatís allowed; however, OSHA Health & Safety Compliance
Officers (thatís what they call their inspectors) really like to see the
safety manual as a stand-alone document, independent of the other policies of
All written plans should be reviewed often and updated whenever necessary to
ensure they are current. Temporary, handwritten changes (in ink) are acceptable
whenever a staff member responsible for an element of the plan leaves the
hospital, but the plan should be retyped and updated when the changes are
extensive or during an annual review.
The plan does not need to be elaborate, just informative. Most practices already
have the elements of the plan in place (meaning a person who makes sure bottles
get labeled and someone who keeps up on the MSDS library) so it just takes
writing down the details on paper.
Make Sure Your Written Hazard Communication Plan
Your written Hazard Communication Standard plan should be comprehensive
enough to address the particulars of everyday situations but simple enough to be
understood. You can start your own plan by following the guidelines given here
or click here for a simple fill-in-the-blank plan
that you can print and use!
- If youíre writing your own plan, be sure to address these issues either
as an integral part of the HCS plan or as separate, individual plans.
- An introduction or explanation outlining the practiceís commitment to a
safe & healthy workplace. This introduction should also identify the
person to contact for more information about the plan.
- An explanation of the system(s) used to identify potentially hazardous
materials. This usually entails the use of signs or labels. Whenever
possible, it is best to include an example of the label or warning sign
directly into the plan. Also include the name of the person who is directly
responsible for ensuring all containers are properly labeled. Click
here for more information on on labeling.
- An overview of the Material Safety Data Sheet (MSDS) filing system.
Identify the location where the MSDSs are kept and the manner in which they
are filed (e.g., alphabetical by product name). Also include the name or
title of the person who is responsible for obtaining MSDSs for new products,
reviewing the sheets for completeness and generally keeping the library
up-to-date. Click here for more information on
maintaining your MSDS library.
- Explain the procedure for getting information and training to employees.
If your practice does not have a formal, written training program, then the
HCS plan should include the frequency and timing of chemical safety training
as well as identifying any video, audio or written materials that will be
used in the training. Be sure to describe the objectives of the training
program - exactly what each employee should understand and apply after the
training is accomplished. The name or position of the person responsible for
administering the training program should also be included.
A list of hazardous materials known to be
on the premises is mandatory. This list must be current and include only
hazardous materials (e.g., a printout from the inventory program showing
every item on hand is not acceptable). As with all the other items,
inclusion of the name or position of the person responsible for the accuracy
of the list is also necessary. (Click here for more
information on determining the hazard potential of a chemical.)
This list is not to identify quantities of each chemical, but merely a
compilation of all the chemicals available - regardless of their quantity.
It's common for a veterinary practice to have OVER ONE HUNDRED FIFTY
hazardous materials on the premises at any one time. Do not depend solely on
purchasing records, as it is typical for "stray" materials to make
their way into a hospital. Remember to include cleaning and maintenance
chemicals, laboratory products, injectable drugs and laboratory chemicals.
Many practices have "stores" of products that they no longer use,
but have not discarded. Remember, presence, not use, is the determining
factor for inclusion on the list. Now may be a great time to clean off those
high shelves in the storeroom!
This may seem like a very time consuming procedure, but it really isn't that
bad. The best way to do this is to start at the front of the clinic and go
through each room writing down all the materials found in the room. Of
course, the pharmacy, treatment room and storage area will take the most
time, but in general this inventory can be completed in about four hours in
most practices. If in doubt, include it; if later that product is determined
to be not hazardous, it can easily be removed from the list. Type the list
into a computer and use the "sort" feature to alphabetize the
list. Duplicate entries can be easily spotted and deleted. The hazardous
materials list is now complete.
More on Hazard Chemical Programs
The information on these pages is excerpted
The Veterinary Safety & Health Digest,
Copyright 2003 Philip J. Seibert, Jr., CVT All Rights Reserved
No part of this publication may be reproduced for distribution without prior
permission from the publisher.