Some urgent care and occupational medicine providers have questions regarding the new OSHA requirement for Safety Data Sheets (SDS), effective June 1, 2016. Essentially, to be compliant you must:
- Make sure all of your Material Data Safety Sheets (MSDS) are replaced with Safety Data Sheets (SDS)
- Assure that all hazards in your urgent care center are labeled with the new pictograms
- Re-up any training you’ve provided employees on OSHA compliance
OSHA requires that employers keep SDS on potentially hazardous materials. These sheets are generally available from the manufacturer, supplier, or online. In 2013, OSHA changed from MSDS to SDS, which is the international standard. This new standard covers more than 43 million workers who produce or handle hazardous chemicals in more than 5 million workplaces across the country. The U.S. Department of Labor predicts this change will prevent >500 workplace injuries and illnesses and 43 fatalities annually. To ensure your facility is in compliance, go through your MSDS binder to verify you have a sheet for all onsite chemicals, and that all the sheets are in the new SDS format. If you have old MSDS sheets (pre-2013), contact your vendor or supplier to get the new sheets for your binder. (Typically, the only hazardous materials in urgent care centers are cleaning supplies, but you should maintain an ongoing inventory of all hazardous materials.)
Another requirement: The chemicals themselves (as well as other potential workplace hazards) must be labeled with pictograms. In most cases, the packaging from the manufacturer will contain the appropriate label. An example of where it may be necessary to use your own label would be if you put a manufacturer’s product into a different container (eg, if you put toilet bluing for drug screens in a spray bottle, the spray bottle needs to be labeled). OSHA provides pictograms and descriptors for this purpose on their website.
For the OSHA training, the requirement is that employees be able to read and understand the SDS and pictogram. This is an ongoing obligation, to ensure that employees understand what chemicals are potentially hazardous, where those chemicals are stored, how to read the labels and SDS sheets, and what to do in case of an emergency. For more information, visit https://www.osha.gov/dsg/hazcom/HCSFactsheet.html