Veterinarians to navigate new rules for hazardous substances

February 7, 2013
By: Jennifer Fiala
For The VIN News Service 

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Veterinarians soon must change how they label and log everything from pharmaceuticals to disinfectants in response to new rules for hazardous substances laid out by the Occupational Safety and Health Administration (OSHA).

By the year’s end, all employers must alert staff that labeling and classification changes are on the horizon. Employers have until June 1, 2016, to fully comply with the new regulations, according to OSHA's timeline for implementing the changes. 

Regulators revised OSHA’s Hazard Communication Standard last spring, adopting the United Nations’ protocols for classifying, labeling and handling hazardous materials. The goal is to reduce confusion about chemical hazards in the workplace by implementing globally recognizable and universal standards.  

Key aspects of the Hazard Communication Standard: 

• Businesses must have a written plan directing employees how to use chemicals safely.
• As part of that plan, businesses must maintain a list of products defined as hazardous.
• A library of safety data sheets must be maintained for all hazardous chemicals on the list.
• All containers of hazardous chemicals must be labeled with proper warnings.
• Employees must be trained to know what the labeled warnings mean, the dangers of hazardous chemicals and safety measures.

The standard's revisions replace material safety data sheets (MSDS), commonly used in veterinary practices, with safety data sheets. The safety data sheets will have a 16-section format similar to the current American National Standards Institute format that’s familiar to U.S. employers. However, the sections have been reorganized to be consistent with the Globally Harmonized System of Classification and Labeling of Chemicals. 

New labels for all chemicals made in the United States and exported abroad also are being established. The labels will include specific hazard warning words and symbols, requiring veterinary practices to update the labels on their secondary containers (spray bottles or other containers used to store small quantities of chemicals) to reflect the new warnings and images.Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
Philip Seibert, a consultant and expert in regulatory requirements for veterinary practices, says veterinarians have plenty of time to decipher the new hazardous-substance rules and develop practical ways to implement them.

“Having said that, certainly you should start educating yourself on the changes and pay attention to the developments,” he said.

Seibert gave that advice to veterinarians and veterinary staff members during a recentdiscussion hosted by the Veterinary Information Network, an online community for the profession. 

Manufacturers are in the process of developing the new labels and updating their safety data sheets to reflect the new regulatory language requirements and pictograms, he said, adding that the new label rules are more complex than what’s currently required.

“...The way the rules are written now will prohibit a type of label with all the warnings and pictograms displayed (the typical fill-in-the-blank format), and will require a unique and specific label for each and every product,” Seibert said.

As for new safety data sheets, he said: “We're just going to have to wait until each manufacturer updates their MSDSs in the new format. They have until June 2015 to do that, so we're just going to have to update our MSDS libraries as they become available.” 

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Preparation Needed by Vets to Comply With New OSHA Labeling Requirements

The Occupational Safety and Health Administration (OSHA) has made changes to its labeling requirements for hazardous materials, revising guidelines that have been around since 1994.
Deadlines for training employees and implementing the changes are not yet urgent, with employee training required by December 2013 and full compliance by June 2015. Even so, many hospitals have not yet even learned of the upcoming changes, according to Laurie Miller, AAHA practice consultant.
Miller, who evaluates several veterinary practices each week, said she estimates only about half of the hospitals she has visited recently have been aware of the changes.
To prevent hospitals from being caught off-guard, NEWStat took a closer look at the new requirements and how practices can prepare for compliance.
Details of labeling requirement modifications
The new OSHA requirements state that as of June 1, 2015, all hazardous materials labels - both primary and secondary - will need to feature:

• Pictograms
• A signal word
• Hazard and precautionary statements
• Product identifier
• Supplier identification

A sample image of the new label can be viewed on the OSHA website.
According to OSHA, the changes are intended to more closely align the Hazard Communication Standard with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals.
Benefits of implementing a globally standardized labeling system include safer handling of chemicals, less confusion in the workplace, and enhanced worker comprehension of hazards, OSHA said on its website.
While compliance will initially mean an adjustment period for veterinary practices, ultimately it will help all employees be on the same page when it comes to dealing with hazardous materials, according to Miller.
“Part of the rationale behind the new rules is to have a more consistent look both to the Material Safety Data Sheets (which will change to the term 'Safety Data Sheets') and the secondary labeling,” Miller said. “The new rules were implemented not to make a veterinary practice’s life miserable, but to state affirmatively that part of the purpose is to harmonize with international requirements.”
Tips for preparing for the requirement changes
Miller shared a few helpful tips for practices so they aren’t unprepared when the changes are officially implemented:

• Avoid procrastination - “While the training must take place by December next year (2013) and full compliance must happen by June 2015, we tend to procrastinate, and the sooner a veterinary team takes care of this the easier the compliance will be with the new program,” Miller said.
• Put someone in charge - Practices should pass the information about the labeling changes along to the person who is in charge of ensuring compliance, such as a safety officer or manager, Miller said. That person can then be responsible for ensuring that employee training and other steps toward compliance are completed on time.
• Check for updates - “Keep checking the OSHA website frequently for more updated information. I am finding that they are updating on a fairly regular basis with new training information and definitions,” Miller said.

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