Manufacturers of chemical products like their products to sound safe. They give them nice names and friendly descriptions: “Sunshine Fresh,” “Safe ‘N Clean,” “Ocean Breeze.” But there is a reason why those containers have warning labels. Quite simply, if it has a warning label, it is a chemical that needs to be used and disposed of carefully.

While the medical profession’s stated goal is health, unfortunately, many of the chemicals used in daily practice are not so healthy. Take a look around your office and see how many things have warning labels. All sorts of things, like electrode jelly, soaps and cleaning chemicals, bleach, mercury-containing compounds, formaldehyde, and glutaraldehyde need to be considered.

Your employees have a right to know about the chemicals being used in their work place. Not only is it their right, it is mandated by law—the Occupational Safety and Health Administration’s Hazard Communication Standard. Now, I realize that OSHA is not an acronym that brings glowing smiles to most doctors’ faces. But remember that the Administration was created for good reasons, and compliance need not be burdensome.

The Hazard Communication Program was put into place to make sure that staff knows about workplace hazards and how to protect themselves. How do you comply with this standard with limited time and resources?

Do an Inventory: Walk through your practice, and look at the products you use—pay close attention to volatile compounds and chemicals used to sterilize instruments or disinfect the office. You can also review your purchasing information. List the names of the products, the manufacturers, addresses, phone numbers and the average amount of each used on a daily basis. This inventory should be updated annually and placed in a three-ring binder.

This is a good time to review the products that you use. Do you use several materials to accomplish the same task? Are there opportunities to reduce the toxicity of your materials? Can you either eliminate, replace or reduce the use of any toxic compounds? Are you using material appropriately? Many people have worked with a product for years before they actually take the time to read the label and learn that they have been using it incorrectly.

Get the Material Safety Data Sheets: If it has a warning label, it needs a Material Safety Data Sheet (MSDS). If this does not come with a product when shipped, you need to obtain it. Most product packages have a phone number or address. Contact the manufacturer and have them fax or mail a copy of the MSDS. These sheets are an OSHA requirement; they provide safety and health information regarding that product. The MSDS must be in English and include the following information:

• Name of ingredients in the product
• Characteristics that make it hazardous
• OSHA’s permissible exposure limit.
• Any symptoms of exposure to this product.

Place the MSDS for each product used in your practice in a 3-ring binder, label it, and let your staff know where it is.

Label All Containers: Any chemicals you use must be labeled. If you use a secondary container, make sure that it is clearly marked with what the product is and its associated hazards. If it is a chemical waste product, put the date on the label as well. Warning signs should be placed throughout your work area, where appropriate.

Air Testing: Read your MSDS’ carefully. Certain chemicals have permissible exposure limits set by OSHA and other agencies. Chemicals such as glutaraldehyde and formaldehyde, used commonly in medical practice, easily vaporize. If the vaporized levels exceed the permissible level, staff could be exposed and you could be violating OSHA standards. Air levels can be tested by consulting with a Certified Industrial Hygienist. OSHA doesn’t say how often testing should be done, but it is a good idea to have it done at least annually and to monitor periodically. You want your staff to work in a safe environment.

To find an industrial hygienist in your area, visit the American Industrial Hygiene Association (www.aiha.org). Click on “Consumer Info” and then click on “Consultant Listing,” then click on your state. This will provide you with a list of certified industrial hygienists in your area.

Have a Spill Management Strategy: Through review of MSDS’, you can learn how to clean up toxic materials safely. Many products have an accompanying spill kit. Both formaldehyde and glutaraldehyde have neutralizing agents. Staff should be trained to prevent and clean up incidental spills.

A safe environment means fewer lost workdays, increased staff morale, and less chance of being fined for OSHA regulation violations, which can range from under $1,000 to tens of thousands, depending on the situation.

For a wealth of information on subjects from ventilation to chemical safety to ergonomics to x-ray safety to hazardous material spill response, visit the OSHA website at www.osha.gov. This site can link you to your local OSHA area office. For OSHA’s health care section, go to www.oshaslc.gov/SLTC/healthcarefacilities/index.html.

As always, please direct your specific questions to: jbrown@bethisraelny.org.

Janet Brown is the medical Waste Manager for Beth Israel Medical Center, New York City. Beth Israel is firmly committed to reducing the volume and toxicity of its waste stream. Many of the strategies that work for Beth Israel can also work for you.