Managing Hazardous Materials

Please note that this page refers to federal requirements.  State and local regulations may differ.  Check the page for your state on the HERC Occupational Safety and Health Resource Locator for links to more information.

The rules that apply to managing hazardous materials inside your facility are mainly concerned with protecting employees who need to work with the materials, and with protecting anyone inside the facility (employees, patients, and visitors) who could be affected by the materials.  The general framework for the rules is largely established by the Occupational Safety and Health Administration (OSHA), the federal agency concerned with worker safety.

Note that once materials have been used, they may fall into the "hazardous waste" category.  As hazardous wastes, the materials will also need to comply with another set of rules (RCRA), established by a different federal agency, the Environmental Protection Agency (EPA).  See the HERC Hazardous Materials -- Overview and Hazardous Waste Determination pages for more information on hazardous wastes.

This section contains information on the OSHA Hazard Communication Standard (HCS) and key hazardous materials topics that can help achieve compliance and reduce waste generation and operating costs. Complying with the HCS is both a legal requirement and good common sense. Good communications, together with good workplace practices should help to reduce the incidence of illness and injuries from chemical sources. Compliance does not have to translate to higher operating costs.  By implementing good operating practices, health care facilities can improve safety, reduce the volume of hazardous materials present, reduce the volume of hazardous waste generated, and lower operating costs.


Hazard Communication Standard

Exposure to certain chemicals can cause or contribute to many serious health effects, including heart ailments, cancer, central nervous system disorders, kidney and lung damage, sterility, burns, and severe skin rashes.  Some chemicals may also be safety hazards and have the potential to cause fires and explosions and other serious accidents. 

Because of the seriousness of these safety and health problems, and because many employers and employees know little or nothing about them, OSHA has developed a framework called the Hazard Communication Standard (HCS).  The basic goal of the standard is to ensure that employers and employees know about work hazards, and know how to protect themselves.

In addition to the Hazard Communication Standard, OSHA has developed a detailed set of rules dealing with specialized topics such as storage of flammable materials, compressed gases (including oxygen), and other materials which are often stored in healthcare facilities.  A list of titles, together with link to the text the rules, may be found at the OSHA website

What is covered under the Hazard Communication Standard (HCS)?

The HCS covers all chemicals imported into, produced, or used in U.S. workplaces.  It establishes uniform requirements to make sure that the hazards of each of these chemicals are evaluated, and that this hazard information is transmitted to employers who deal with the chemicals and to employees who might be exposed to them.

Note first that this applies to all hazardous chemicals.  The HCS covers both physical hazards (such as flammability) and health hazards (such as irritation, lung damage, and cancer).  Most chemicals used in the workplace have some hazard potential, and thus will be covered by the rule.

How does the HCS work?

The standard's design is simple.  Chemical manufacturers and importers are responsible for evaluating the hazards of the chemicals they produce or import.  Using that information, they must then prepare labels for containers, and more detailed technical bulletins called material safety data sheets (MSDSs).

Employers that “use” hazardous chemicals must have a program to ensure that this information is provided to exposed employees.  “Use” means to package, handle, react, or transfer.  This is an intentionally broad scope, and includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.

In other words, your chemical supplier is responsible for ensuring that the appropriate evaluation has been performed and that the material is available to you, but you (as a healthcare facility) are responsible for making sure you have obtained the information and have communicated it to anyone in your workplace who may be affected by it.

One difference between this rule and many others adopted by OSHA is that this one is performance-oriented.  That means you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific rigid requirements.  It also means that you have to exercise more judgment to implement an appropriate and effective program. 

Are you located in a "State Plan" State?

If you are operating in a state with an OSHA-approved State Plan, you must comply with your State's requirements, which may be different from those of the Federal rule.  Many of the "State Plan" States had hazard communication or “right-to-know” laws prior to promulgation of the federal rule.  Employers in State Plan States should contact their State OSHA Offices for more information regarding applicable requirements.  Use the HERC state OSHA locator to determine if you are located in a state with an approved OSHA program.

The remainder of this section describes how to prepare a written hazard communications program, which is a key requirement of the Hazard Communication Standard.  Other sections in Managing Hazardous Materials cover important elements such as purchasing materials, inventory control, labeling, storage, and materials segregation.  These practices will help you comply with the rules in a cost effective manner.  Also, there is a list of additional resources that may further improve your understanding of these rules and assist with compliance.

 

Written hazard communication program

Employers must develop, implement, and maintain at the workplace a written, comprehensive hazard communication program.  The written plan should include:

  • who is responsible for the various aspects of the program in your facility,
  • a list of hazardous chemicals in the workplace (hazard inventory),
  • how the requirements for labels and other forms of warning, materials safety data sheets, and employee information and training, are going to be met in your facility.

The written program does not have to be lengthy or complicated.  Some healthcare facilities may be able to start with an existing written program from another facility and adapt it to their own facility.  Several example programs can be found under More Resources

Although these examples may be helpful, you must remember that the written program has to reflect what you are actually doing in your workplace. You can use the example as a basis to get you started, but expect to do some rewriting.  You will need to adapt it to address the specific circumstances in your facility. It is not a good idea simply to write up the plan, and then to file it away and forget it.  The regulations specify that your written program must be available to

  • employees and their designated representatives
  • the Assistant Secretary of Labor for Occupational Safety and Health (i.e. to the OSHA inspector, if he or she requests it)
  • the Director of the National Institute for Occupational Safety and Health (NIOSH)

In addition, in states with state plans, you may also be asked to make your program available to the appropriate state authorities.  It is worth the effort to review the plan periodically to make sure it covers any changes that may have occurred in your facility or your range of operations.  At a minimum, that will make it more likely that your staff will know where to find the written plan if someone asks to see it.

The rest of this section deals with several specific topics that your written hazard communications program must address, including:

Each of these items is covered in more detail in the following paragraphs.

 

Identifying responsible staff

Compliance with HCS is not a "one shot deal".  Hazard communication will be a continuing program in your facility.  In order to have a successful program that will both protect your employees and pass inspections, you must assign responsibility to specific individuals.  This applies both to the initial activities (plan writing and getting the facility into compliance in the first place) and to ongoing activities.

In some cases, these activities may be part of current job assignments. For example, Site Supervisors are frequently responsible for on-the-job training sessions. If you identify which employees will be responsible for implementing the plan and get them involved early in the program design process, your plan will be carried out more effectively.  You will also get feedback that will help you evaluate the program.

For any safety and health program, success depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires a change in behavior. This will occur only if employers understand the program and are committed to its success, and if the people presenting the information motivate employees.

You can refer to the written program examples listed below for ideas on establishing roles and responsibilities.

 

Hazard inventory

As part of your written hazard communication program, the standard requires you to prepare a list of all of the hazardous chemicals in the workplace.  The list will eventually serve as an inventory of everything for which you must maintain an MSDS.  But even from the outset, preparing the list will help you complete the rest of the program, since it will give you some idea of the scope of the program required for compliance in your facility.

The best way to prepare a comprehensive list is to survey the workplace.  Purchasing records are also useful for establishing what chemicals have entered the facility "officially".  You should of course review them, create a list, and determine the fate of all purchased chemicals once they have been received.  But materials also have a way of flying into facilities under the radar (as vendor samples, for example).  There is no substitute for actually walking through the facility, clipboard in hand, looking in all the nooks and crannies, and taking copious notes.

The broadest possible perspective should be taken when doing the survey.  Sometimes people think of 'chemicals' as being only liquids in containers.  The HCS covers chemicals in all physical forms„ liquids, solids, gases, vapors, fumes, and mists whether they are 'contained' or not.

During the survey, try to take a comprehensive look around:

  • Identify the chemicals in containers, not forgetting to include chemicals contained in pipes.
  • Think also about chemicals that may be generated during facility operations.  For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures.
  • Read labels provided by the suppliers on hazard information.
  • Make a list of all chemicals in the workplace that are potentially hazardous.

For your own information and planning, you also may want to note on the list the location(s) of the products within the workplace, and an indication of the hazards as found on the label.  This will help you as you prepare the rest of your program. To determine whether a particular chemical is covered by the rule, you should consider two factors:

  • Can the chemical pose a hazard under any plausible circumstances?
  • What is the potential that someone in the workplace might be exposed to the chemical?

If the chemical is inherently non-hazardous, it is not covered (water, mild solutions of innocuous substances, etc.).  If there is no potential for exposure, (for example, if the chemical is

MSDS collection and availability

Once you have compiled as complete a list as possible of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received material safety data sheets for all of them.  Check your files against the inventory you have just compiled.  If any are missing, contact your supplier and request one.  It is a good idea to document these requests, either by copy of a letter or a note regarding telephone conversations.

If you have MSDSs in your files for chemicals that are not on your list, figure out why.  Maybe you don't use the chemical any more.  Or maybe you missed it in your survey.  Some suppliers do provide MSDSs for products that are not hazardous.  These do not have to be maintained by you.  If you have questions regarding the hazard status of a chemical, contact the manufacturer, distributor, or importer.

You should not allow employees to use any chemicals for which you have not received an MSDS.  The MSDS provides information you need to ensure you have implemented proper protective measures for exposure.

Having gone through this exercise once, you will not want to have to repeat it too often.  You will find it advantageous to have procedures in place to confirm that the appropriate MSDS has been received and is on file in the right location before any material your facility receives is released for use in the workplace.

The MSDS is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures. Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a downstream distributor or user. Distributors also must ensure that downstream employers are similarly provided an MSDS.

Each MSDS must be in English and include information regarding the specific chemical identity of the hazardous chemical(s) involved and the common names. In addition, information must be provided on the physical and chemical characteristics of the hazardous chemical; known acute and chronic health effects and related health information; exposure limits; whether the chemical is considered to be a carcinogen by NTP, IARC, or OSHA; precautionary measures; emergency and first-aid procedures; and the identification (name, address, and telephone number) of the organization responsible for preparing the sheet. Copies of the MSDS for hazardous chemicals in a given worksite are to be readily accessible to employees in that area. As a source of detailed information on hazards, they must be readily available to workers during each workshift.

Employers must prepare a list of all hazardous chemicals in the workplace. When the list is complete, it should be checked against the collected MSDSs that the employer has been sent. If there are hazardous chemicals used for which no MSDS has been received, the employer must contact the supplier, manufacturer, or importer to obtain the missing MSDS. A record of the contact must be maintained.

Labels and other forms of warning

In-plant containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings.  Chemical manufacturers, importers, and distributors must ensure that every container of hazardous chemicals they ship is appropriately labeled with such information and with the name and address of the producer or other responsible party.  Employers purchasing chemicals can rely on the labels provided by their suppliers.  If the material is subsequently transferred by the employer from a labeled container to another container, the employer will have to label that container.

The primary information to be obtained from an OSHA-required label is the identity for the material and appropriate hazard warnings.  The identity is any term which appears on the label, the MSDS, and the list of chemicals, and thus links these three sources of information.  The identity used by the supplier may be a common or trade name ("Black Magic Floor Cleaner"), or a chemical name (1, 1, 1 - trichloroethane).  The hazard warning is a brief statement of the hazardous effects of the chemical ("flammable," "causes lung damage").  Labels frequently contain other information, such as precautionary measures ("do not use near open flame") but this information is provided voluntarily and is not required by the rule.  Labels must be legible and prominently displayed.  There are no specific requirements for size or color or any specified test.

With these requirements in mind, if you are inspected, the compliance officer will be looking for the following types of information to ensure that labeling is properly implemented in your facility:

  • Designation of person(s) responsible for ensuring labeling of in-plant containers;
  • Designation of person(s) responsible for ensuring labeling of any shipped container;
  • Description of labeling system(s) used;
  • Description of written alternatives to labeling of in-plant containers (if used); and,
  • Procedures to review and update label information when necessary.

Training

Employers must establish a training and information program for employees who are exposed to hazardous chemicals in their work area at the time of initial assignment and whenever a new hazard is introduced into their work area.  At a minimum, the discussion topics must include the following:

  • The hazard communication standard and its requirements.
  • The components of the hazard communication program in the employees' workplaces.
  • Operations in work areas where hazardous chemicals are present.
  • Where the employer will keep the written hazard evaluation procedures, communications program, lists of hazardous chemicals, and the required MSDS forms.

The employee training plan must consist of the following elements:

  • How the hazard communication program is implemented in that workplace, how to read and interpret information on labels and the MSDS, and how employees can obtain and use the available hazard information.
  • The hazards of the chemicals in the work area.  (The hazards may be discussed by individual chemical or by hazard categories such as flammability.) Measures employees can take to protect themselves from the hazards.
  • Specific procedures put into effect by the employer to provide protection such as engineering controls, work practices, and the use of personal protective equipment
  • (PPE).
  • Methods and observations, such as visual appearance or smell, workers can use to detect the presence of a hazardous chemical to which they may be exposed.

Purchasing/Receiving/Inventory

Purchasing Procedures

Good purchasing procedures will identify and reduce potential waste before it enters your business:

  • Material Review:  Evaluate the materials used by your business, look for less- or non-toxic substitutes, and purchase:
    • The least toxic and least costly-to-handle products that work
    • Higher-purity raw materials
    • Noncorrosive raw materials
  • Container Review:  Consider your intended use and standard operating practices, and purchase materials in the size and type of container which will minimize material losses and costs:
    • Buy in smaller containers if transfer from large to smaller containers is generally required before use (There will be less potential for spills, material evaporation, contamination from unused material returned to the original container, and expiration of unused materials.)
    • Buy in pre-weighed packages to reduce handling losses (if applicable)
    • Buy materials used often in larger containers (Buying in bulk can reduce the number of containers requiring disposal, especially if refillable containers are used.)
    • Buy containers that are wider than tall (They have less "cling," resulting in greater material use and less container residue.)
    • Buy containers which minimize disposal problems (e.g.  fillable pressurized spray cans in place of single use aerosol spray cans)
  • Chemical Samples:  Establish a policy for accepting samples so they do not accumulate and add to waste disposal load:
    • Designate one person responsible for acceptance of chemical samples
    • Test on a bench scale basis to reduce volume needing disposal
    • Require that suppliers accept back the unused samples they provide
  • Equipment Evaluation:  Prior to purchase, ensure that new equipment:
    • Is that which will generate the least amount of hazardous waste possible
    • Can be easily maintained (Preventive maintenance can save 3-4 times the equipment cost by reducing breakdowns and malfunctions.)
    • Complies with applicable environmental and safety standards (Check with regulating agencies.  Use suppliers knowledgeable in these areas.)
  • Centralized Purchasing:  Channel material purchases through a central person or department to:
    • Eliminate unnecessary purchases
    • Ensure that all waste reduction purchasing policies are followed
  • MSDSs:  Make certain that distributors supply you with Material Safety Data Sheets for all purchased hazardous materials in order to:
    • Know material hazards, proper safety precautions, and handling and emergency response procedures
    • Comply with OSHA worker (Link to applicable HERC page) and EPA (Link to applicable HERC page) community Right-to-Know laws
    • Help you determine the nature of your wastes
  • Evaluate Facility Design:  Consider waste reduction when planning expansions, and evaluate potential building purchases/leases to determine whether the building design is amenable to waste reduction.  Make sure that:
    • Hazardous materials storage areas exist or can be easily installed
    • Space and utilities are available for proper recycling and treatment needs, etc.

Receiving Procedures

Good receiving procedures will prevent acceptance of shipments which are off-spec, incorrect, or improperly packaged, and reduce unnecessary waste generation, returns, and spills:

  • Control all incoming materials by:
    • Receiving them in a specific, designated area
    • Designing the area to prevent and control release of materials
  • Train receiving dock employees on proper handling of shipments to prevent property losses, injuries, and costly waste disposal
  • Inspect shipments prior to acceptance:
    • Check for opened, damaged, or leaking containers
    • Check expiration dates and ensure proper labeling
    • Test for off-spec materials
    • Obtain MSDS if product is new (Employers must maintain a MSDS for any hazardous chemical stored or used in the work place.)
  • Use quality suppliers (quality and reliability are as important as cost):
    • Supplier should deliver goods intact and according to your specifications
    • Check the track record of your supplier with other companies or references
  • Review or create purchase agreements:
    • Specify terms and conditions for receiving material orders
    • Include provisions which allow you to inspect materials prior to acceptance
    • Address responsibility in the event of a release (Specify terms under which each party is responsible for cleanup or other expenses incurred to control an incident.)
  • Document agreements to ensure that specified procedures are followed (Remember, suppliers want your business and should be willing to ship on your terms.  If not, try to find another supplier or change products.)
  • Comply with Emergency Planning and Community Right-To-Know Act (EPCRA) Section 311 requirements (link to applicable HERC page) (Healthcare facilities must submit copies of hazardous chemical material safety data sheets (MSDS) or a list of MSDS chemicals to the LEPC, SERC, and local fire department).

Inventory Control Procedures

Inventory control procedures are important for reducing management costs and potential hazards associated with excess, off-spec, and expired materials:

  • Set Inventory Limits:  Set according to emergency response capacity.  (How large an inventory can your spill/emergency response equipment and personnel handle? The more inventory of hazardous materials, the greater the chance for overcrowding storage areas and resulting safety problems such as spills, exposures and fires.)
  • Minimize Inventory:  Buy and stock only what you need (Costs associated with hazard risks, hazardous materials fees, and disposal of excess or expired stock may outweigh the costs of waiting for resupply shipments.):
    • Carefully consider large purchases (especially if only to get a discount)
    • Time deliveries to coincide with production needs ( "just-in-time" system)
  • Track Materials:  Effectively track the shelf-life of time-sensitive materials and use the oldest stock first ("first-in, first-out"):
    • Label, date, and inspect new materials as they are received
    • Keep records of dates of receipt and usage to help reduce overstock and material degradation
    • Inventory raw materials at least once per year
    • Consider computerizing your tracking system
  • Storage Conditions:  Maintain proper temperature, humidity, etc.  to reduce material degradation
  • Reduce the Number of Similar Products (e.g.  If you use several types of solvents, could fewer do the job? Reducing the number of solvents would improve inventory control and enhance recycling opportunities.)
    • Look for substitutes with longer shelf lives
    • Use waste exchanges for overstock, off-spec, or expired materials
    • Work with vendors to accept back excess, off-spec, or expired materials

Additional information on purchasing, receiving and inventory control:


Labeling

Proper labeling is extremely important to prevent accidents and extra disposal costs:

  • Satisfy the OSHA labeling rules for “labels and other forms of warning”
  • Ensure proper labeling of all incoming materials as they are received (Include product name, weight, concentration, lot number, date, hazard class and any other information useful in tracking material location, quality, age or use.)
  • Always label hazardous waste at its point of generation where it can still be easily identified (Subsequent testing to determine the contents is expensive.)
  • Label all stationary tanks, pipelines, etc.  containing hazardous materials or wastes
  • Label all portable "squeeze" bottles

Additional information on labeling:

  • HMIS and NFPA Labeling Systems (link to applicable HERC page)
  • Emergency Planning and Community Right-To-Know Act (link to applicable HERC page)
    Storage

Well-designed hazardous materials and waste storage areas minimize and contain spills and provide for easy inspection of containers:

  • Use high quality, resealable containers to prevent spills, evaporative losses, and contamination; and keep the lids/seals closed when not in use
  • Arrange raw materials storage with access to front and back of shelving so new materials can be placed behind older stock
  • Keep raw material and waste storage area aisles clear of obstructions:
    • Allow elbow room to access all containers easily and minimize spills
    • Space containers to allow inspection for corrosion and leaks
    • Maintain clear, even surfaces on pathways used by workers or equipment
  • Keep storage areas clean and well-lit
  • Stack containers no higher than recommended by manufacturer, in a way which minimizes the potential for tipping, tearing, puncture, or breakage
  • Don't stack equipment against containers
  • Make sure containers and shelving or storage areas are earthquake safe
  • Insulate electrical circuitry and check frequently for corrosion and potential sparking
  • Raise drums off floor to prevent corrosion from concrete "sweating"
  • Provide secondary containment and maintain proper distance between different materials
  • Install sloped concrete floors and curbs or berms for spill containment in areas such as vehicle maintenance
  • Cover outdoor storage areas to prevent contamination of storm water
  • Secure storage areas to minimize liability and hazards of intrusion or dumping

Additional information on storage:


Raw Material Use and Handling

More efficient utilization of raw materials will reduce losses and unnecessary waste generation:

  • Ensure that employees:
    • Use supplies only for their intended purpose
    • Use only the amount necessary
    • Have access to MSDS as required by OSHA rules. (link to applicable HERC page)
  • Keep frequently used hazardous materials near the site of use to minimize spills/accidents
  • Provide transfer methods which prevent spills and quality problems:
    • Pipelines for intermediate transfer
    • Gravity spigot or pump to dispense bulk liquid materials
    • A spout and funnel for transferring liquids to different containers
    • Proper connection/disconnection of hoses and lines
  • Control access to hazardous raw materials:
    • Designate central personnel to distribute materials
    • Limit access to employees trained in hazardous materials handling and who understand the importance of first-in first-out policy
  • Keep records of when and why larger spills occurred in order to identify spill prevention opportunities and document related costs

Additional information on storage:

  • To be added.