Hazard Communication Program

As part of the HCS, employers are required to develop a hazard communication program. The hazard communication program consists of a written plan that describes what the facility is doing to meet the requirements of the HCS. The information in the plan must be made available and communicated to all employees who work with hazardous chemicals.

Inventory of Hazardous Chemicals

The employer must develop and maintain a list of hazardous chemicals that are used and stored in the workplace. This list must include the name of the chemical, the name of the manufacturer, the hazardous ingredients, and the health and safety ratings of the chemical. The list must be updated as new chemicals are introduced into the workplace. In the medical office, hazardous chemicals often include the following:

Labeling of Hazardous Chemicals

The HCS requires that each container of a hazardous chemical be labeled by the manufacturer with a warning to alert the user that the chemical is dangerous (Figure 18-1). This label must include the possible hazards of the chemical and the steps that can be taken to protect against those risks. Hazard warnings can use words, pictures, or symbols to provide the user with an understanding of the physical and health hazards of the chemical. If a label falls off a product or is damaged or obscured, a replacement label must be applied. If a chemical is transferred to a new container, a label with all the required information must be attached to the new container.

Material Safety Data Sheets

A material safety data sheet (MSDS) provides more detailed information than the container label regarding the chemical, its hazards, and measures to take to prevent injury and illness when handling the chemical (Figure 18-2). The HCS requires that a current MSDS be kept on file for each hazardous chemical used or stored in the workplace. MSDSs must be readily accessible to employees and provided to them on request. It is important that the medical assistant review the MSDS before working with a hazardous chemical.

Companies that manufacture and distribute hazardous chemicals must provide an MSDS with every product. A hazardous chemical should never be used unless an MSDS is available. In the event of an accidental exposure, information on the MSDS must be readily available as a reference for emergency treatment. If an MSDS is missing, it must be replaced. This can be accomplished by contacting the supplier or the manufacturer of that chemical for a replacement or by going to the manufacturer’s website; most manufacturers post their MSDSs on their websites for easy access.

An MSDS does not have to be kept on file for a hazardous chemical that is used in the workplace in the same way that a household consumer would use it. For example, correction fluids, such as Wite-Out and Liquid Paper, contain a hazardous chemical. If the medical assistant uses it in the same way, however, that a household consumer would use it (i.e., to correct errors on a document), an MSDS does not need to be kept on file. If household bleach (sodium hypochlorite) is used to decontaminate blood spills in the medical office, an MSDS would need to be kept on file because the bleach is not being used in the same way that a household consumer would use it.

Material Safety Data Sheet Requirements

The HCS requires that manufacturers of hazardous chemicals include the following information on the MSDS (see Figure 18-2):

1. Identification. This section provides information used to identify the chemical and must include the chemical’s generic name and its brand name; the name, address, and emergency phone number of the manufacturer; and the date the MSDS was prepared.

2. Composition of ingredients. This section provides a list of the ingredients in the hazardous chemical and exposure limits of each chemical.

3. Physical and chemical properties. Physical and chemical properties of the chemical must be listed in this section, such as appearance, odor, boiling point, and freezing point.

4. Fire and explosion data. Some hazardous chemicals may cause a fire or explosion if used improperly. This section indicates under what circumstances this may occur and what to do if it does occur, including recommended extinguishing agents.

5. Reactivity data. Some chemicals react when combined with other chemicals or materials. The reactivity data list the substances and conditions that the chemical should be kept away from to prevent a dangerous reaction. This information helps in determining where and how to store the chemical.

6. Health hazard data. This section is one of the most important areas for health care workers and includes the following information:

• Route of entry, which indicates how the chemical can enter the body, including skin contact, eye contact, inhalation, and ingestion

• Signs and symptoms of overexposure (e.g., burning eyes, nausea, dizziness, difficulty in breathing)

• Medical conditions that are aggravated by exposure to the chemical (e.g., asthma, dermatitis)

• Acute and chronic health hazards that could result from overexposure (e.g., skin irritation, eye damage, lung damage)

    This section also indicates whether the hazardous chemical has been identified as a potential carcinogen by the National Toxicology Program (NTP), the International Agency for Research on Cancer (IARC), and OSHA.

7. Emergency first-aid procedures. This section identifies the first-aid measures to take if exposed to the chemical (e.g., in case of eye contact, immediately flush eyes with water for 15 minutes).

8. Precautions for safe handling and use. This section tells what to do for a spill or leak, the method of disposal of the chemical, and how to handle and store the chemical.

9. Control measures. This section lists engineering controls, work practice controls, and personal protective equipment that should be used to protect oneself from the hazardous chemical. Examples of these measures include using chemical-resistant gloves and eye protection and working in a well ventilated area.

Putting It All into Practice

My name is Kara VanDyke, and I work for two physicians in a family practice medical office. As a medical assistant, one of the situations you deal with on an almost daily basis is drug representatives who come to the office to promote their products. Their job is anything but easy. The waiting and the frequent rejections would make most people think twice before applying for the job.

One winter day, I am sure I made one drug representative really think twice about his career choice. As the representative stopped at our office, he, being a polite young man, let a patient enter the building first with wet, snow-covered feet. Trying to make a good impression with a new suit and dress shoes, he soon found himself doing a “Spanish fandango” while trying to maintain his balance and eventually crashed to the floor.

I thought I would help by mopping up the snow-tracked floor. What I did not know was the mop had wax on it. Needless to say, when he returned with the requested drug samples, we were not able to keep him from falling a second time! 

Employee Information and Training

The HCS requires that employees be provided with information and training regarding hazardous chemicals in the workplace. The training session must be offered at the time of an employee’s initial assignment to a work area where hazardous chemicals are present, and whenever a new chemical hazard is introduced into the work area. The training program must be an ongoing activity, and each training session must be documented. The HCS requires that the following information be relayed to employees who work with hazardous chemicals:

Sanitizing Instruments

Items most frequently sanitized in the medical office are medical and surgical instruments. This section focuses on the theory and procedure for sanitizing instruments. The general steps in the sanitization procedure of instruments are as follows:

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