The use of chemical agents in healthcare organizations is an essential task to ensure effective disinfection and sterilization of equipment, patient care treatments and as a fixative for tissue specimens. It is essential that organizations follow safe handling, storage and use practices that are designed to safeguard staff and their patients. These safeguards are designed to reduce exposure to hazardous chemicals or ineffective action from improper preparation. Failures in following prescribed exposure and handling requirements can also result in significant fines from the Occupational Safety and Health Administration (OSHA).
Safety Data Sheets
Safety Data Sheets (SDS) are the backbone for safe use and handling of hazardous chemicals by listing the hazards and other safety considerations for hazardous chemicals. The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)) requires that chemical manufacturers, distributors, or importers provide an SDS for each of their hazardous chemicals to users to communicate information on these hazards. These hazards are addressed in the standardized sections of each SDS. The information would include:
- Chemical Identification
- Identification of Hazards
- First Aid Measures
- Fire Fighting Measures
- Handling Considerations
- Storage Requirements
- Accidental Spill Procedures
- Exposure Controls / Personal Protection
- Stability and Reactivity
- Toxicology Information
- Transportation Requirements
- Ecological Considerations
The information from the SDS is essential in guiding staff on how to properly handle and use hazardous chemicals. Frequently our consultants find organizations that do not have SDSs readily available for use or their SDSs are outdated. Other organizations may provide access to the SDS though a website, but staff are unfamiliar with how to access them or interpret the information contained. OSHA requires organizational leaders to ensure that the SDSs are readily accessible to staff members for all hazardous chemicals in their workplace and they know where to find them. “Readily available” is defined in the OSHA Brief DSG BR-3514 2/2012 as “ immediate access to the information without (staff) leaving their work area” which includes both digital and hard copy format. Additionally, any digital format should have a backup in the event of a power outage or computer network interruption. This could include distributing hard copy binders with current SDSs.
Leaders should also ensure that SDSs are properly maintained. This would include ensuring that all chemicals in use have SDSs distributed for use as well as a process to ensure that any updates to the SDS by the chemical manufacturer are reflected in their SDS inventory. Organizations may wish to designate a responsible individual to oversee the SDS process.
Chemicals must be stored safely to be ready and available for staff when they are needed for use. This includes storing chemicals in the proper environment (temperature, humidity, ventilation, light exposure) as defined in the SDS. There also may be limitations on intermixing chemicals with each other in storage due to potential volatile reactions. The SDSs should be referenced for any storage limitations. Containers must have lids or caps securely in place to prevent spills and exposure risks. The storage area should be clean and free of spillage and debris. There should also not be any unauthorized chemicals in use or in storage.
Chemicals must be labeled appropriately to inform users on safe handling and use. Information on labeling requirements can be found on OSHA DSG BR-3636 2/2013 briefing sheet. All labels are required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. Supplemental information can also be provided on the label as needed.
There are also requirements for chemicals that are placed in secondary containers such as beakers and other containers for use. This would require labeling if the material is not used within the work shift of the individual who makes the transfer, or they leave the work area. If the container is moved to another work area and is no longer in the possession of the worker who filled the container, there would need to be labeling compliant with the OSHA requirement.
There are other labeling requirements on OSHA DSG BR-3636 2/2013 that should be reviewed by leaders overseeing chemical use and storage for additional guidance. Organizations should adopt a labeling process that meets their needs.
Safe handling practices must be followed to prevent accidental staff and patient exposure. The predominant opportunity our teams find include staff not complying with proper Personal Protective Equipment (PPE) use as mandated by the SDS. Survey observations of the locations where exposure to hazardous chemicals occur often find a lack of PPE in storage and unavailable for use. Other observations include the use of the incorrect PPE type. This would include use of gowns or eye protection not authorized for chemicals that may be corrosive. The use of fabric gowns (not splash proof) and/or eyeglasses (not face shields/splash goggles) will not provide adequate protection from accidental exposure. Reference the hazardous chemical’s SDS for guidance on proper PPE. Additionally, reference the instructions for use of the PPE to ensure it aligns with the proper protection level as defined by the instructions for use. There may also be confusion about storing clean PPE in a soiled location which is often where chemicals are located - we should provide guidance here. Is it okay? IF no, what is permissible?
In the event of accidental exposure, staff must have access to the appropriate eye wash/shower devices indicated per the SDS. Often, our teams note that eye wash/shower stations are not in compliance with the ANSI/ISEA Z358.1-2014 requirements. These observations include:
- Exposure risk not in required proximity to eye wash stations in terms of time/distance to access
- No mixing valves for eye wash stations to regulate temperature allowing the eyewash to deliver the correct temperature water by activating a single handle/paddle
- Stations blocked by supplies or equipment
- Stations located behind locked doors when the exposure risk is located outside of these spaces
- Stations not in good working order (dirty water, mold in eye caps, sediment)
- Eye wash stations mounted on soiled sinks
- Missing maintenance/ testing logs for stations
- Testing process does not meet established requirements
- Expired eyewash solutions
With accidental leaks or spills, it is imperative that staff have access to the proper supplies and equipment to restrict the spread of the hazardous chemical and perform proper clean up to avoid exposure. These spill kits must be available and correspond to the requirements of the SDS of the chemicals in use to ensure they will be effective in clean up. Leaders must ensure staff are trained in the use of the spill kits (or have a trained responder team) and any associated procedures.
Another opportunity that our consultants occasionally observe is that staff members are not mixing chemical solutions, often diluting them with water, to the proper concentration or in a safe manner. Diluting chemicals must be performed per the Instructions for Use and by the SDS. If chemicals are not diluted enough, this could result in solutions that contain too much chemical agent which may damage or destroy equipment and pose a greater risk of exposure. If chemicals are too dilute, then the solution may not be effective in cleaning/disinfecting as needed. To avoid these issues, leaders must ensure that staff are trained on dilution procedures, and they are provided equipment/supplies that support effective practice such as graduated containers and measuring devices that allow accurate measurement. Leaders should observe staff performing these dilution procedures to ensure they are following proper preparation steps and are using safe practices.
Safe use of hazardous chemicals is imperative for the safety of staff and patients. Unfortunately, it is often not a top priority for healthcare organizations who are challenged with addressing the complexities of patient care. Organizations should devote time to periodically review their hazardous chemical use including safety data sheets, storage, labeling and handling practices. This could be a part of the annual review of your hazardous chemical inventory. When is the last time you reviewed your hazardous chemical use?
For more information, check out the following resources:
- The National Institute for Occupational Safety and Health (NIOSH) Chemical Hazard website: https://www.cdc.gov/niosh/topics/healthcare/chemical.html
- OSHA Hazard Communication Guidance: https://www.osha.gov/hazcom/guidance
- The American National Standards Institute (ANSI) ANSI/ISEA Z358.1-2014 International Standard for Emergency Eye Wash and Shower Equipment
To learn more about hazardous chemical safe handling practices contact the C&A team at 704-573-4535 or email us at email@example.com.