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Safety Data Sheets: An Overview and Call to Action

In the healthcare setting there are many chemicals that we encounter and work with. The aim of this article is to review and, in some cases, inform people of what their rights to safety are regarding these products and how the new hazard communication system works. The specific focus will be on the safety data sheets (SDS), which tell us everything we want to know regarding chemicals we are working with, near, or are potentially exposed to. We will focus on specific aspects of these sheets that are often overlooked: spill-response measures and how they are organized, stored, and accessed. First, let’s do an overview of safety data sheets.

The Globally Harmonized System (GHS) is the international approach to hazard communication for chemicals and is part of the newly revised Hazard Communication Standard.

The new safety data sheet system has changed how chemicals are labeled and formatted. The former material safety data sheets (MSDS) presented sometimes fragmented information in an inconsistent arrangement. There was a dire need for a standard format. The changes have created a globally harmonized format of new safety data sheets that are more efficient, more effective, and communicate consistent information no matter who the manufacturer or supplier is. The changes and the new system do not just apply to the United States. We live and work in a global economy with chemicals coming from all over the world. Adopting GHS around the world has ensured the protection of workers internationally.

Adopting and following the program has saved money and, more importantly, has saved lives. It is estimated this revised Hazard Communication Standard can prevent 43 deaths and 585 injuries or illnesses per year, as well as save an estimated $475 million per year by improving the quality, consistency, and clarity of hazard information that workers receive.

As mentioned earlier under the new Global Harmonized System, material safety data sheets are now called safety data sheets. Not only does the name change, but the format and information contained in the SDS have changed to a standardized format with 16 headings. Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., firefighting). This information should be helpful to those that need to get the information quickly.

  • Section 1: Identification – Identifies the chemical on the SDS and its recommended uses; provides contact information of the supplier
  • Section 2: Hazard(s) Identification – Identifies the hazards of the chemical and appropriate warning information
  • Section 3: Composition/Information on Ingredients – Identifies ingredient(s) contained in the product, including impurities and stabilizing additives; includes information on substances, mixtures, and all chemicals where a trade secret is claimed
  • Section 4: First-Aid Measures – Describes initial care that should be given by untrained responders to an individual who has been exposed to the chemical
  • Section 5: Fire-Fighting Measures – Provides recommendations for fighting a fire caused by the chemical
  • Section 6: Accidental Release Measures – Provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup to prevent or minimize exposure to people, properties, or the environment
  • Section 7: Handling and Storage – Provides guidance on safe handling practices and conditions for safe storage of chemicals
  • Section 8: Exposure Controls/Personal Protection – Indicates exposure limits, engineering controls, and PPE measures that can be used to minimize worker exposure1

Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision.

  • Section 9: Physical and Chemical Properties – Identifies physical and chemical properties associated with the substance or mixture
  • Section 10: Stability and Reactivity – Describes reactivity hazards of chemical and chemical stability information; broken into three parts: reactivity, chemical stability, and other
  • Section 11: Toxicological Information – Identifies toxicological and health effects information or indicates that such data is not available
  • Section 16: Other Information – Indicates when SDS was prepared/revised; may state where changes have been made to previous versions; other useful information1

Sections 12, 13, 14, and 15 are regulated by other agencies (i.e., EPA, DOT).

  • Section 12: Ecological Information – Provides information to evaluate the environmental impact of the chemical(s) if it were released into the environment
  • Section 13: Disposable Considerations – Provides guidance on proper disposal practices, recycling, or reclamation of the chemical(s) or its container, and safe handling practices
  • Section 14: Transport Information – Provides guidance on classification information for shipping and transporting of the hazardous chemical(s) by road, air, rail, or sea
  • Section 15: Regulatory Information – Identifies safety, health, and environmental regulations specific for the product that is not indicated anywhere else on SDS1

Employers in the United States have specific responsibilities with hazardous materials and safety data sheets. These include the following employer responsibilities under OSHA 29 CFR 1910.1200:

  • Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced
  • Maintain copies of SDSs received with incoming shipments
  • Obtain SDSs as soon as possible for chemicals received without an SDS if the employee requests the SDS
  • Ensure that SDSs are readily accessible during each work shift to employees when they are in their work area(s)
  • Ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked properly
  • Ensure that employees are provided information and training to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container
  • In multi-employer workplaces, ensure that employees of other employer(s) will have on-site access to SDSs for each hazardous chemical they may be exposed to while working, are informed of any precautionary measures needed to protect themselves under normal operating conditions or in foreseeable emergencies, and are informed of the labeling system used in the workplace2

OSHA also requires that employers develop, implement, and maintain a written hazard communication plan. The written program should document:

  • Designated person(s) responsible for obtaining and maintaining SDSs
  • How SDSs are maintained in the workplace (e.g., notebooks in the work area[s] or electronically); how workers obtain access to them when during the work shift
  • Procedures to follow when an SDS is not received at the time of the first shipment
  • SDS for each chemical in the workplace and training of workers that includes a review of SDS format and use

OSHA gives workers and their representatives the right to see the information that employers collect on hazards in the workplace. Workers have the right to know what hazards are present in the workplace and how to protect themselves. Healthcare, and specifically sterile processing, is no exception when it comes to hazardous materials. There are many types of chemicals used in cleaning, disinfection, and sterilization. It is imperative to follow OSHA regulations for labeling and ensuring safety data sheets are available.

You can ask the following questions to begin understanding whether your facility is compliant with OSHA regulations:

  • Where are safety data sheets located
  • Are they in book form or digitally accessible via computer or online database? Online databases have the easiest accessibility and are easier to keep up to date
  • Who is responsible for them in the hospital and in your department, specifically

Once you understand the basics for safety data sheet requirements, you can check your compliance for each chemical in your department.

For example, let’s focus on Section 7: Handling and Storage. Are your chemicals stored properly according to the SDS sheet requirements? This could include temperature and humidity requirements, security measures, or spillproof fire cabinets.1

One section that is often found to be out of compliance is Section 6: Accidental Release Measures. When a product spills or leaks, this section will inform workers on what to do to contain the material and make the area safe. Many facilities are not prepared to follow the specifics of what the SDS may require by not having the correct materials or not having enough of the correct materials based on how much hazardous chemical is stored in that area.1

Let’s look at an example from an SDS for Wavicide-01. Section VI – Accidental Release Measures says to “[W]ear appropriate protective gear such as gloves, apron, and protective eyewear. Absorb with a suitable absorbent (such as paper towels) and store in a suitable container for disposal. Large spills may be neutralized with sodium bisulfite (about 200 g/gallon), glycine, or ammonia.”3

If your facility carries this product, are you prepared for spills? Do you have the appropriate spill-response products listed above and are they nearby to the potential spill area? Are they in the right quantities to handle your largest spill? There may also be a scenario where both spill and disposal measures are required to be covered.

Another example that most can relate to is surgical bone cement in a sterile storage area that is ruptured or damaged before use.

Take these considerations to heart and make them your to-do takeaway so that you are informed and most importantly prepared to respond to any hazards in the workplace.

References

  1. OSHA (Occupational Safety and Health Administration), “Hazard Communication Standard: Safety Data Sheets,” Washington, DC. 2012. Accessed December 8, 2020, https://www.osha.gov/Publications/OSHA3514.html
  2. OSHA (Occupational Safety and Health Administration), “Workers’ Rights,” Washington, DC. 2017. Accessed December 8, 2020, https://www.osha.gov/Publications/osha3021.pdf
  3. Medical Chemical Corp., “MSDS for Wavicide-01,” Torrance, CA. 2015. Accessed December 8, 2020, http://www.med-chem.com/msds/0112.pdf

David Jagrosse, CRCST, CHL, has 30 years of experience in CSSD/SPD as a technician, supervisor, and manager. He was the Connecticut Central Service Association communications officer (1998–2000), vice president (2006–2008), and served three terms as president (2009–2015). David was a member and chairman of the ASHCSP Recognition Committee. He works with the AAMI Standards Work Group 40 (ST79) as an active voting member that develops guidelines in CSSD, and is the director of the oneSOURCE Speakers Bureau. David is active with IAHCSMM as a member of the orthopedic council and speaker at annual meetings, and has served IAHCSMM in many capacities, including president (2015–2016). He has been published in Communiqué/Process, Infection Control Today, Healthcare Purchasing News, and AAMI Horizons. David is a consultant for AAMI-based audits to CSS/OR audiences internationally.

 

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