What an OSHA inspector checks in a HazCom review: a checklist for clinics

Hazard Communication is consistently among OSHA's most frequently cited standards. In healthcare practices, the gaps are rarely dramatic: a binder that hasn't been touched in years, a spray bottle with no label, a new assistant who was never shown where the SDSs are. Here is what an inspector reviews, requirement by requirement.

1. A written hazard communication program — 1910.1200(e)(1)

You need a written program that describes how you meet the labeling, SDS and training requirements, and that includes a list of the hazardous chemicals known to be present. The list should match what is actually on your shelves, and the product identifiers should match the SDSs.

2. Workplace labels — 1910.1200(f)(6)

Original containers keep the manufacturer's label. Secondary containers — the disinfectant you decant into a spray bottle, the solution in an ultrasonic cleaner — need the product identifier and the hazards, either in full or through an alternative system your staff are trained on.

3. An SDS for every hazardous chemical — 1910.1200(g)(1)

Every hazardous chemical in the workplace needs a current Safety Data Sheet. Some products are exempt — for example, drugs in solid, final form for direct administration to the patient, and consumer products used in the same way and at the same frequency as a consumer would use them. When in doubt, keep the SDS.

4. Ready access on every shift — 1910.1200(g)(8)

SDSs must be readily accessible to employees in their work area during each work shift. Electronic access is allowed when it creates no barriers to immediate access — no login an assistant doesn't have, no single computer in a locked office. Inspectors may ask a staff member to find a specific SDS.

5. Training — 1910.1200(h)(1)

Employees must be trained at the time of their initial assignment and whenever a new chemical hazard is introduced. Training covers how to detect releases, the physical and health hazards, protective measures, and how to read labels and SDSs. Keep records of who was trained and when.

The checklist

• Written program on file, with a current chemical list
• Every container labeled, including secondary containers
• A current SDS for every hazardous product
• SDSs reachable by every employee on every shift
• Training at hire and when new hazards are introduced, documented