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What is involved in setting up a hazard chemical program for the hospital?

HMIGpost.jpg (86968 bytes)When 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 be valid.

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 the hospital.

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 Covers:

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.

    paws.gif (897 bytes) More on Hazard Chemical Programs

    The information on these pages is excerpted from
    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.

 

 

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This page was last updated on 01/24/14.

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