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Chemicals Exempt from the HCS

These categories of products are exempt from the entire provisions of the HCS:

• Hazardous waste - This material is regulated by the Environmental Protection Agency, and not OSHA.
  
• Tobacco or tobacco products - Regulated by the FDA not OSHA.
  
• Articles - These are products made up of hazardous materials, but when the manufacturing process is complete, the finished item poses no hazard during foreseeable use, e.g., autoclave tape, thermometers and x-ray marking tape.
  
• Food or nutritional products (including vitamins, IV fluids and milk replacement formulas.
  
• Foods, drugs, or cosmetics intended for personal consumption by employees while in the workplace.
  
• Any common consumer product that is used in substantially the same manner (frequency, duration & quantities) as normal consumer use. This means things like window cleaner, laundry detergent, liquid correction fluid, etc. can be exempted unless your hospital uses these products differently than the average consumer. Be careful though; some normal consumer products like peroxide, alcohol or even bleach would not be exempted because the typical veterinary hospital would use these products at a greater frequency than the normal consumer
  
• Any drug (medication) when it is in solid final form for direct administration to the patient (e.g., tablets or pills). This exemption does not apply if the pills are crushed or dissolved prior to administration nor does it apply to capsules, liquids, gels or powders.

These are total exemptions from the standard which means that the chemicals can be unconditionally excluded from the program. There are other exemptions for retail establishments where employees NEVER open the package of chemicals and for shipping operations where employee exposure is unlikely. These exemptions are generally not useful in the veterinary profession.

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The information on these pages is excerpted from
The Veterinary Safety & Health Digest,
Copyright 2003-2001 Philip J. Seibert, Jr., CVT  All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission from the publisher.