Compliance

Checklist: Hazard Communication Standard (29 CFR 1910.1200)

This standard is set to ensure that hazards in medical and dental offices are classified and communicated to employers and employees to prevent harm. Facilities often use or store hazardous substances that can harm human health. To protect the health of workers, OSHA formulated the Hazard Communication Standard to help employees understand and train in proper ways when handling hazards in the workplace.

Here is a sample checklist to help you comply with the Hazard Communication Standard:

Hazard Communication Program

Availability of the program to employees and designated representatives, and the secretary of labor to OSHA

  •  Have a written Hazard Communication Program with the following:

Procedures for evaluation and description of hazards (with help from the manufacturer or importer)
Tested all hazardous materials in workplace (with help from manufacturer or importer)
Procedure of labeling system
List of hazardous materials referenced on MSDS (Material Safety Data Sheet, more on it below)
Description of employee education and training
Description of hazards in non-routine tasks
Handling procedure for hazards of non-labeled pipes
Procedures for informing on-site contractors of the hazardous substances in the workplace to which their employees may be exposed

List of Hazardous Materials in the Workplace

 Raw materials
 Isolated and non-isolated intermediates
 Final products
 Cleaning and maintenance chemicals
 Laboratory chemicals with MSDS information
 Waste products not regulated under the Resource Conservation and Recovery Act (RCRA), but classified as hazardous under this standard
 Impurities and by-products
 Waste treatment and products

Hazardous Materials Labeling System

Labeled all products containing hazardous materials
Labeled all products containing hazardous materials leaving the workplace
Labeled stationary containers
Labeled temporary containers used between work shifts
Have a procedure to ensure that labels are correct and up-to-date

Content of Hazardous Materials Label

  • Labels of hazardous materials must contain the following:

Chemical name corresponding to its name in the MSDS
Identity of hazards with words (English), pictures or symbols
Hazards detailing immediate and direct consequences of mishandling
Information in compliance with DOT regulations
Information in compliance with other OSHA standards, if material is regulated
Name and address of responsible party

Material Data Safety Sheets

A MSDS available for every hazardous chemical in the workplace
Readily accessible MSDS available to exposed employees

In-house Labeling System

Labeled containers with the identities of hazardous chemicals and clear hazard warnings
Placed hazard warning materials for hazardous chemicals in stationary process containers in readily accessible places
Checked and made sure that labels of incoming containers are not removed or defaced
Used labels that are clearly legible and in English
Identified and labeled hazards in pipelines

Established Procedures for the Following:

Updated MSDS (may require help from supplier)
Took appropriate action for shipment without accompanying MSDS
Advised employees regarding updates/changes to the MSDS
Introduced a new and updated MSDS to employees handling materials
Made and documented efforts to get a MSDS from supplier

Written Procedures on Assessing Hazards of Non-routine Tasks

Have procedures for identifying use and exposure to hazardous materials
Have procedures assessing hazards involved in performance of non-routine tasks
Obtained MSDS for hazardous materials involved in these non-routine tasks
Have labeling system or procedure to identify hazardous substances and hazards involved in these non-routine tasks
Have special training procedures for performance of non-routine tasks

Employee Education and Training

Informed employees on the availability of training for hazardous materials handling
Informed employees on the availability of training for the Hazard Communication Standard, including a hazardous chemical list and MSDS
Informed employees on the availability of training for operations with hazardous materials
Training of employees, including temporary ones, before they start to work with hazardous materials
Updated training for employees who have transferred jobs or departments
Updated training procedures to accommodate significant changes in operations or chemicals

  • Training procedures must include the following:

Information about physical and chemical hazards in the work area
Detecting the presence of hazardous materials – monitoring procedures, odors and visibility, etc.
Proper use of appropriate PPE
Emergency procedures in the event of contact or accidental exposure to hazardous materials, using emergency phone numbers and eye washes and showers
Determining hazards in a label
Reading and understanding MSDS
Locating and obtaining a MSDS and procedures for each particular hazardous chemical (e.g. using trade name as identifier)
Updating MSDS and obtaining updated copies from the supplier/manufacturer/importer
Measures to protect from chemical exposures (e.g. proper handling of hazardous materials, using PPE)
According to OSHA, this guide only provides the minimum set of standards that address frequently found hazards in medical and dental offices. Many other standards still apply, and it is the employer’s responsibility to follow up and obtain full texts of OSHA standards. All workplaces must display the OSHA poster in places where workers will see it.

All standards are available on the OSHA website (www.osha.gov) or by calling toll-free number (800) 321-OSHA (6472).

This is the most applicable, most requested and most referenced OSHA standard in medical and dental offices. This standard aims to prevent the spread of bloodborne pathogens, which can result in serious diseases like AIDS and chronic hepatitis. Medical and dental offices often have to deal with situations where splashes of blood-tainted substances may occur, which is inevitable. The Bloodborne Pathogens Standard was established to reduce or prevent harm to workers while they perform their jobs.

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