CFR 1910 1200 OSHA Hazard Communication Standard This

§ CFR 1910. 1200 OSHA Hazard Communication Standard § This program was established so that employee’s will be informed of the contents of the Hazard Communication Standard, the hazardous properties of the chemicals with which they work, safe handling procedures and the measure to take to protect themselves from hazardous chemicals. § This standard was revised. The changes have been made to labeling requirements, MSDSs are now referred to as SDSs with added sections, and training requirements have been revised to align with the UN Globally Harmonized System of Classification and Labeling of Chemicals.

Use the following checklist to help you comply with OSHA HCS 2012: • Audit your chemicals: conduct a physical audit of all chemicals in the workplace • Confirm the use of workplace labels: as you conduct your inventory, ensure all containers are properly labeled • Obtain updated supplier SDSs: contact the manufacturer for a current SDS for each chemical in the workplace • Distribute your supplier SDSs: ensure your chemical users have FREE, unlimited access to the updated SDSs • Train your employees: update your existing hazardous chemical training program to include the GHS data elements and format of the SDS

§ A representative from each clinic/lab will maintain up a list of all products that contain hazardous chemicals used in their clinic or laboratory § This will be referred to as the hazardous chemicals inventory list (HCI) § This list will be kept in front of the SDS book for reference § This list will be updated as new chemicals are introduced into or removed from the clinic

§ SDSs are detailed information bulletins prepared by the manufacturer or supplier of any product that contains a chemical deemed to be hazardous § The SDS has 16 sections: üIdentification, Hazard(s) Identification, Composition/Information on Ingredients, First-Aid Measures, Fire-fighting Measures, Accidental Release Measures, Handling and Storage, Exposure Controls/PPE, Physical and Chemical Properties, Stability and Reactivity, Toxicological Info, Ecological Info, Disposal Considerations, Transport Information, Regulatory Information, and Other Information

§ If an SDS is not available refer to the online SDS Public Service Library at http: //www. chemquik. com/scripts/mai n. asap

• Labels will list the chemical identity of the material, appropriate hazard warnings and the name of the manufacturer • The manufacturer is responsible for labeling the original container, however, it is the ultimate responsibility of the PM or lab supervisor • Professional products that are regulated by the FDA are exempt from labeling except when transferred to a secondary label

§ Labels for hazardous chemical must contain: ü Name, address, and telephone number ü Product identifier ü Signal word ü Hazard statement(s) ü Precautionary statement(s) ü Pictogram(s)

OSHA HCS 2012 Labels Under OSHA HCS 2012, chemical manufacturers and importers must label their chemical containers with the applicable GHS elements. In turn, employers must convey these GHS elements on the workplace label for each hazardous chemical. These GHS elements include: • Signal Word: “Danger” or “Warning” indicates the severity of the hazard. • GHS Pictograms: convey the health, physical and environmental hazard information assigned to a specified GHS hazard class and category. • Health and Physical Hazard Statements: describe the nature and degree of the stated hazard. • Precautionary Statements: describe measures to minimize or prevent effects from exposure or improper storage of the hazardous chemical.

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§ Chemicals transferred to a secondary container need to be labeled § Examples of secondary containers include: alcohol, bleach, disinfectant, radiographic chemicals § Every container that you place a chemical in needs to be labeled…including, ultrasonic cleaners and radiographic processors

§ Hazard Communication training must be updated to include the new label and SDS formats and how to implement these changes

§ Hazardous waste storage containers must be in good condition, free of leaks and compatible with the material stored in them § The container should remain capped when not in use § If the container should begin to leak, place in a larger non-leaking container, transfer to another container and call the safety office at 433 -7556 is needed § All containers must be marked with the words “waste” or “spent” § Kept near the site of generation and under control of the generator § Compatible with contents (no acids in metal cans)

§ Kept closed at all times except when in use § Properly identified with waste tags before pickup § Transported with a non-leaking screw on cap § Filled to a safe level (not beyond the bottom of the neck of the container or a 2 inch head space for 55 gallon drums) § Do NOT use red bags or sharps containers for storage

§ A generator of potentially hazardous waste may accumulate up to a total of 55 gallons of waste which may be determined to be hazardous or one quart of acutely hazardous waste § In the event more than this volume will be generated, contact Safety for a special pick-up § Hazardous waste in excess pf 55 gallons may not be stored at your site for more than 3 days § Refer to the Department of Safety Procedures for Disposal of Hazardous Waste Manual for details on which chemicals are compatible and incompatible

§ Prior to pick-up a waste tag is required (refer to the Laboratory Safety Manual for details) § This should be filled out by the waste generator and attached to each container § When ready for disposal contact the Safety department. § A hazardous waste disposal request form will need to be filled out (refer to the Laboratory Safety manual) § An SDS should accompany the container

§ The Safety department conducts regular safety inspections of all labs § Failure to comply may result in disciplinary action

§ At no time will any chemical be disposed of by pouring it down the drain regardless of what is recommended by the SDS or manufacturer § Dental developer and fixer chemicals shall be stored in containers provided by the chemical transporter and disposed of as hazardous chemicals

§ Dental amalgam is a potential source of mercury vapor § Dental amalgam waste & teeth containing amalgam will be placed in the designated containers placed in each operatory § Each container will be labeled appropriately § A designated vendor will pick up used amalgam § Lead foils will be collected in a plastic container § The container will be labeled appropriately § The container will be picked up monthly by a designated vendor.

§ All unused, unneeded, or expired prescription drugs must be removed from their original containers and mixed with used coffee grounds, kitty litter, or other undesirable substances. § The litter or coffee grounds must be placed in impermeable containers such as zip-loc baggies and then in the trash to prevent diversion. Disposition of medications must include the medication name, strength, prescription number (if applicable along with patient's name), quantity, date of disposition, and disposing staff or students.

Medications should NOT be placed into sharps containers. Syringes containing medications should be emptied into kitty litter which will then be enclosed in zip-lock bags, and disposed of in the trash unless on the previous list. Syringes will then be disposed of in the correct manner.

The Board of Pharmacy recommends that any expired bottles (used or unused) of injectable controlled substances be sent for reverse distribution to: Return Logistics International Corporation, 22 Artley Road, Savannah, GA 31408.

§ You are responsible for the safety of your clinic or lab § If you do not know the chemicals properties ask for help § Proper PPE is required to include lab coats, and safety glasses when handling chemicals, biohazards, and radioisotopes § No shorts, sandals, or open toe shoes § No children or pets § Never pipette by mouth § Be aware of dangling jewelry, hair, and loose clothing § No food in designated refrigerators § Never work alone. If not avoidable let someone know where you are

§ Wash hands frequently and always before leaving the lab § Do not wear PPE outside of the lab § Contact lenses should not be worn in lab § Work areas should be kept clean and free of unnecessary chemicals § Clean equipment after use to avoid cross contamination § Do not block emergency exits or equipment § Do not eat, drink, apply make-up or chew gum

§ Emergency phone numbers should be posted near entrances to each lab, storeroom and beside every phone in the lab or clinic § Include Emergency Medical Services, The RSO, and the Office of Safety

§ Fire-Pull the nearest fire alarm. If you are unable to control or extinguish a fire follow building evacuation plan § Accidents-attend to person who may have been contaminated if it is safe to reach them. Use safety showers and/or eye washes as appropriate. Flush eyes for a minimum of 15 minutes and seek medical attention immediately. § Ingestion of substance- call Poison Control Center at 1 -800 - POISON § Skin Contact-wash skin with water and remove clothing or jewelry. If symptoms persist seek medical attention. § Spill- notify persons in the immediate area. Evacuate all non- essential personnel

§ Flammable spill- Turn off all ignition sources. Avoid breathing vapors. Be aware some chemicals have no odor or create olfactory fatigue(you stop smelling the odor quickly) § Leave on or establish all exhaust ventilation and close doors to prevent spread of the odors § Call Emergency Services 1 -911 in case of fire, if there is immediate threat to life, or any other emergency situation

§ Be aware of marked exits § To activate the fire alarm, pull the handle on one of the red boxes located in the hall § In the event of a fire, call 1 -911 § If the fire alarm sounds, exit through the nearest exit § Proceed to designated assembly area and check in with designated personnel § Do not return to the building unless instructed by Security § Refer to the Emergency manual for detailed instructions for building evacuation and other emergencies

§ Be aware of which products contain hazardous chemicals § Know what hazards are associated with these products § Know the proper hygiene for working with dental products § Know what to do in case of a spill § Know the location of your spill kit § Have the necessary supplies on hand

§ In the event of a MINOR spill utilize the spill response equipment. Specific contents of the spill kit may be found in the Laboratory Safety Manual. § Refer to SDS to determine cleanup method § Use appropriate PPE § Cover liquid spills with absorbent material (check compatibility) § Cover powdered materials with wet paper towels § Neutralize corrosive if appropriate materials available § Clean from the outer area towards the center § Place spilled material in impervious container, seal, and contact Safety Department for disposal § Wash/mop up area § A solvent (xylene) may be necessary to clean surfaces contaminated with a non-water soluble chemical

v. The Spill-Kit container should include: § Chemical spill instructions § Utility gloves and protective eyewear § Kitty litter, vermiculite or a 50. 50 mixture of the two § Sodium bicarbonate (Baking soda) § Plastic non-sparking scoop § Plastic bags § Dust pan § Paper towels § Fresh 1: 10 bleach solution

§ Respond only if you have been trained…otherwise summon assistance § Attend to anyone contaminated or injured if safe to reach them § Call Emergency Services (1 -911) § If room equipped with UV lights, turn them on § Evacuate non-essential personnel. Leave the lab and close doors § Remove contaminated clothing and place in impervious container, seal and label, avoid contact with others, take a shower § Put on PPE

§ Wait 30 minutes for aerosol to settle before entering § Turn off UV lights and check for visible mists before entering § Apply appropriate disinfectant to spill with gentle flooding action to avoid secondary aerosols § Cover excess liquid with absorbent material and dry material with wet paper towels § Place spill clean-up material into a container and autoclave or call Safety Department for disposal § Wash affected surface with strong disinfectant

§ Procurement ü Before a substance is received information on proper handling, storage and disposal must be known. Refer to SDS ü All chemicals must be properly labeled § Stockrooms/Storerooms ü Chemicals must be segregated and stored properly depending on their properties ü Stored chemicals should be examine periodically (at least annually)for leakage and to make sure labels are secure § Distribution ü When moving chemicals place in an outside secondary container ü Use freight elevators whenever possible when transporting chemicals

§ Laboratory Chemical Storage ü Read labels carefully before storing ü Store according to the Chemical Storage Segregation Scheme in the Laboratory Safety Manual ü Store all chemicals by their hazard class not in alphabetical order ü Do not store near heat sources or in direct sunlight ü Date chemicals when received and first opened ü Do not use lab benches as permanent storage for chemicals ü Inspect chemicals routinely

ü Do not store chemicals in glass containers on the floor ü Do not use fume hoods as permanent storage areas ü Contact Safety Department for disposal of old, outdated or unused chemicals ü Do not store chemicals above eye level ü Do not store excessive amounts of chemicals in the lab ü Store in proper storage cabinets(Refer to safety manual for specific requirements for storing in these cabinets) • Flammable storage cabinets • Acid storage cabinets • Compressed gas cylinder cabinets

§ Laboratory inventory posters including emergency contacts must be posted outside of each work area § Labels must be placed on all chemical containers § Secondary containers must be labeled § Waste disposal tags must be used to identify waste § Employee notification posters must be current and posted-The Right To Know (can be obtained from Safety Department) ü Florida Hazard Communication Act rights for employees ü Lab supervisor must keep this poster up to date § Safety signs for safety equipment, first aid equipment & exits § Warning signs where special or unusual hazards exist § Food and beverage consumption and storage permit signs

§ Follow laboratory procedures for assembly of lab apparatus (refer to § § § § Lab Safety Manual) Follow laboratory procedures for use of lasers(refer to Lab Safety Manual) Follow laboratory procedures for safe use of cooling baths and cold traps(refer to Lab Safety Manual) Follow laboratory procedures for safe use of vacuum pumps (refer to Lab Safety Manual) Examine electrical cords periodically Make sure all electrical equipment is grounded Do no run cords along the floor where they create a tripping hazard or above the ceiling Do not plug too many cords into one outlet

§ Equipment and other materials should be placed at least 6 inches behind the sash § When hood not in use pull the sash all the way down § Do not keep loose paper or towels in the hood § Do not use as a storage cabinet § When using large equipment keep it raised 1. 5 inches off the work surface to allow ventilation § Do not block fume hood do not modify the fume hood § Minimize the foot traffic in front of a hood

§ Reference the Laboratory Safety Manual for specific details for working with: ü Embryotoxins ü Chemicals with chronic or high acute toxicity ü Substances of high chronic toxicity ü Flammable solvents ü Oxidizers ü Corrosives ü Reactives

§ Refer to laboratory Safety Manual for specific details for working in the different biosafety level areas.

• OSHA requires that all gas cylinders be • • secured to prevent tipping Always use appropriate regulator on cylinder Be legibly labeled and marked to clearly identify the department and gas Be stored to protect against external heat sources Do not use oil or grease on any cylinder Be stored as not to be damaged by passing or falling items Valve protectors must also be in place when cylinder not in use Valves must be closed if cylinder is being moved Inspected regularly

§ Never use cylinder if it cannot be positively identified § Place all cylinders so the main valve is accessible § Remove regulators from all unused cylinders and place protective safety cap § Store oxygen at least 20 feet from a flammable material § Never roll a cylinder § Never drop or strike a cylinder § use designated wrenches or tools to open valve § Store compatible gases together

§ Lab supervisor or program manager or designee will be responsible to assure that Incident Reports are filed with Security § Medical records associated with an exposure will be maintained by the facility in accordance with State and Federal regulations § If a medical consultation is performed HR will obtain a written opinion from the examining physician to include: ü Follow-up recommendations ü Results of the exam ü Statement that the lab personnel has been informed of the results and any follow-up treatment needed § SDSs will be available in each lab for all hazardous chemicals

§ Every lab worker must be trained to know the location and proper use of PPE (refer to the Laboratory Safety manual-”Basic Rules and Procedures for Working with Chemicals”) § Training must be provided at the time of initial employment and then annually or as needed when a new chemical is introduced § Training must include at minimum: ü Location of the Laboratory Safety Manual ü Locations of SDSs ü The permissible exposure limits (PEL) for OSHA regulated substances or the exposure limits for other chemicals where there is no OSHA standard (refer to appendix for PEL’s in Laboratory Safety manual) ü Signs and symptoms of exposures ü Methods to detect the presence or release of a hazardous chemical ü The physical and health hazards of the chemicals in their work area ü The measures lab personnel can take to protect themselves from the hazards ü The applicable details of the Laboratory Safety manual

§ Hazard Communication training is required when the employee is hired and then annually or as needed to include: ü Chemical labeling (new CHS requirements) ü SDSs ü Spill clean-up and chemical disposal ü Chemical storage guidelines ü Hazards specific to different chemical groups ü Implementing new formats

§ Lab safety training must take place at the time of hire and then annually or as needed and must include: ü Safety equipment and practices ü Emergency procedures ü Emergency equipment ü Waste disposal § Fire Extinguisher training is required for all lab personnel ü What to do in the event of a fire ü The behavior of fires ü The classes of fires and proper selection and use of a fire extinguisher § Waste Management Training and Bloodborne Pathogen Training must take place at the time of hire and then annually or as needed. (the requirements covered previously in BBP section)