Navigating the OSHA Hazard Communication Standard in LTC Communities

OSHA; Regulations; Workforce
 

In addition to infectious disease, ergonomic, and workplace violence issues, workers in health care settings encounter several other workplace hazards. These include chemicals (e.g., sterilants), hazardous drugs (e.g., antineoplastic drugs), materials that cause allergic reactions (e.g., latex), and sometimes physical agents (e.g., radiation). 

The Hazard Communication Standard, also known as the "Right to Know" standard, was enacted by OSHA to ensure that employers and employees are aware of the chemical hazards present in their workplace. The standard provides a comprehensive framework for classifying, labeling, and communicating information about hazardous chemicals to workers. It also requires employers to implement a written hazard communication program and provide training for employees. 

Applicability to Long Term Care

Health care communities use various chemicals for cleaning, sanitation, and medical treatments. While many make an effort to use less hazardous chemicals to promote resident or patient safety, the presence of any hazardous chemicals still triggers the applicability of OSHA’s Hazard Communication standard for employee safety. As such, identifying and minimizing potentially hazardous chemicals in a health care community, as required by the Hazard Communication standard can both enhance resident safety and protect employees.

Key Components of Compliance: 

  1. Chemical Inventory: Long Term Care (LTC) facilities and communities must maintain a comprehensive inventory of all hazardous chemicals used on-site. This includes cleaning supplies, medical treatment supplies, and any other substances that pose potential hazards. The chemical inventory serves as the starting point for implementing the Hazard Communication Standard. 

  2. Safety Data Sheets (SDS): LTC employers are required to obtain and maintain Safety Data Sheets for each hazardous chemical in use. These are required to be available from the manufacturer or supplier of the chemical. SDSs provide detailed information on the properties, hazards, safe handling, and cleanup of chemicals​.  

  3. Labeling​: Containers of hazardous substances must be labeled with the following: 
    1. Product name.  
    2. Signal word - such as “Danger” or “Warning.” 
    3. Hazard Statements - describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
    4. Precautionary Statements – describes recommended measures such as safe handling, use, storage.  
    5. Pictogram(s) of the hazards. 
    6. Name, address and telephone number of the chemical manufacturer, importer, or other responsible party. ​​
      • With only rare exception, there should be no unlabeled bottles or containers in the facility.  

  4. Employee Training: OSHA mandates that employees receive training on the hazards of chemicals present in the workplace and the protective measures in place. Training should cover the use of personal protective equipment (PPE), emergency procedures, pictograms found on chemical labels, and the importance of reporting any unsafe conditions. Employees should also know where SDSs can be found in the facility. 

  5. Written Hazard Communication Program: LTC providers must develop and implement a written hazard communication program. This program outlines how the facility will comply with the Hazard Communication Standard, including procedures for labeling, SDS management, and employee training. 

Conclusion: 

By taking proactive measures such as maintaining accurate chemical inventories, providing comprehensive employee training, and implementing clear labeling practices, LTC facilities and communities can create a secure environment where the risks associated with hazardous chemicals are minimized. Embracing the principles of the Hazard Communication Standard not only promotes a culture of safety but also underscores a commitment to the health and welfare of everyone within the LTC setting. 

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