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How do we know which chemicals are hazardous?

Perhaps the most frustrating part of this regulation is determining exactly which chemicals are hazardous. The assumption must be that a chemical is hazardous unless it is one of the exempt items (see below) or until it is proven otherwise by objective data. Start by reading the label; if there are warnings such as, "Caution, Danger, Warning, Toxic, Flammable, Reactive or Corrosive", then it is most likely considered a hazardous material. If the label does not contain such a warning (many drugs do not contain these warnings) check the package insert or accompanying literature for warnings. The determination of a chemical’s hazard status is based on the presence of health or physical hazard to workers. Many materials that have used for years without apparent trouble and never thought of as hazardous could become a real danger in certain situations. It's also known that every person reacts to chemicals differently; substances that apparently have little effect on one person can be severely irritating to another, so it’s better to err on the side of caution when making the determination of a chemical’s hazard potential.

Health hazard - means a chemical for which there is statistically significant evidence based on at least one study...that acute or chronic health effects may occur in exposed employees.

A chemical is considered a health hazard if it falls into one of the following categories:

• Carcinogen
• Toxic (reproductive, hepato-, neuro-, nephro-, hemato-)
• Irritant
• Sensitizer
• Any agent which damages the lungs, skin, eyes, or mucous membranes.
  

Physical Hazard -means a chemical for which there is scientifically valid evidence that it is:

• a combustible liquid,
• a compressed gas,
• explosive,
• flammable,
• an organic peroxide,
• an oxidizer,
• pyrophoric,
• unstable (reactive), or
• water-reactive.
  

It’s easy to see that almost any chemical can fit into this list somewhere. Although the manufacturer of the chemical relays this information to the user on the label and the MSDS, employers do have the ability to alter the severity of the hazard to suit the situation. For instance, in a concentrated form, a particular chemical may be an acute health hazard, but once the chemical is diluted to the concentration that is used in the hospital, the health hazards are very minimal. The employer has a great deal of latitude in this area, but there must be a sound, scientific basis for these decisions.

When two or more chemicals are mixed together, the result could be a simple compound of the two or it may be a different chemical altogether. When a practice mixes chemicals (e.g., for a special ear or hoof treatment) and their employees are exposed to them, the practice may be held to the requirements of a chemical manufacturer. These requirements include the scientific testing of the chemical as well as the preparation of a MSDS detailing its properties. OSHA rarely gets involved in the situation when medications are mixed and dispensed directly to the client. However, if the solution/mixture is made up in advance and could affect employees, OSHA would look closely at the hazard!

Exemptions

As with every rule, there are exceptions. Although OSHA's mandate is to protect workers from occupational injuries and illnesses, they recognize that some products which could fall into the category of "hazardous" are so commonly used, employees are in no more danger in the workplace than in their homes.  Click here to see a list of EXEMPT items!

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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.