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Hazardous material officer: opportunity for laboratorians.

By McDonnell, Romaine
Publication: Medical Laboratory Observer
Date: Monday, April 1 1991

Hazardous material officer: Opportunity for laboratorians

Here's a job to help lab workers increase their professional visibility in the hospital while creating a safer workplace.

Millions of health care professionals gained the right to know about hazardous substances in the work

environment when the OSHA Expanded Hazard Communication Standard was applied to hospital workers on May 23, 1988.

Hospitals across the nation have since had the responsibility to develop policies for identifying and managing hazardous material. This material must be monitored "from cradle to grave"--that is, from the moment it arrives in the facility until its safe disposal. In addition, health care facilities in some states must meet the requirements of new legislation covering safe drinking water and toxic air contaminants.

Hospitals that fail to meet these standards risk being fined or denied accreditation or financial support. Courts have held that employees injured by hazardous chemicals in a facility with no right-to-know program are entitled to collect civil damages as well as workers' compensation. Besides the legal implications, the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) has added to its standards a requirement that every hospital have a right-to-know policy implemented by an effective program.

The furor is understandable. Working in a health care facility may involve exposure to many kinds of chemical hazards. Health care workers are regularly exposed to numerous toxic materials. The long list of chemicals covered under the new laws can be intimidating even to experienced risk managers and safety officers.

* Opportunity. Now is an excellent time for laboratorians to use their knowledge of chemicals toward a new focus: by serving as hazardous material officer. Service of this kind is a good way to augment professional recognition and personal visibility. Here are a few first steps:

*Research. Gather as much information as possible about the new laws and regulations. Because many states, counties, and cities have established standards relating to the OSHA Standard, obtain copies of all those that apply to your institution. Study them carefully.

*Evaluate. With the information in hand, assess the impact of the regulations on your hospital. A background in chemistry, laboratory safety, or laboratory management is a real asset in this regard. For example, you may find that the type of chemistry kit used in your lab is exempt from Environmental Protection Agency (EPA) classification. If the hospital still sterilizes with ethylene oxide, a suspected carcinogen and mutagen, it must inform and protect employees, patients, and the surrounding community from related potential dangers.

*Report. Outline the requirements and your evaluation of their potential impact on the hospital for your risk manager or safety committee. Committee members will appreciate reports that are concise, complete, and well presented. You might create a video or slide presentation to illustrate your main points.

Explain in detail how, as hazardous material officer, you would help to keep the hospital's liability at a low level. Describe how you would implement the OSHA Standard. Include specific reasons for potential public concern over hazardous material, such as the increased risk for leukemia to children whose parents have been exposed to toxic chemicals.(1) The risk manager or safety committee will share this concern and endorse your effort to safeguard the public health.

* Written program. You have been appointed; congratulations. Begin by drafting a written program that meets OSHA's requirements, which include:

*Employee training. You will need policies and procedures that describe how staff members will be informed and trained. A general in-service should be held at the time of hiring, followed by training specific to each department in the laboratory. Additional training is warranted whenever a new chemical hazard is introduced and when significant changes in chemical hazards occur. Notification and retraining are needed if you switch brands of disinfectant to one that contains a greater proportion of a toxin, for example, or if you increase the purchase volume of your regular disinfectant.

*Contractor hazards. OSHA requires the establishment of procedures for informing outside contractors and their employees about hazards. It mandates procedures for obtaining information from contractors about toxic material in their repertoire. Flooring contractors, for example, may use vinyl chloride, which is toxic, as an adhesive. Everyone who will have physical contact with the adhesive has the right to know about the presence of vinyl chloride as well as to receive information about self-protection.

*Data sheets. Your written plan must describe how the Material Safety Data Sheet (MSDS) requirement will be met. An MSDS is a fact sheet that describes the chemical makeup of a material and includes information on stability, inflammability, health hazards, cleanup procedures, and protective equipment. Under the new standard, chemical manufacturers, importers, and distributors are required to provide data sheets to all facilities that purchase their products. Employers must keep a file of information about every hazardous chemical in the workplace. The MSDS file must be readily accessible to every employee on every shift.

*Labeling. Laboratorians are well acquainted with strict labeling requirements. The OSHA Standard requires that containers of hazardous material be labeled with an appropriate warning. Original containers are labeled by the manufacturer, but what if material is poured into a secondary container? According to the OSHA Standard, that container must be labeled with the same cautionary information as the original. Instead of copying everything onto the new label, hospitals can use a pictorial label (the biohazard symbol, for example) or the National Fire Protection Agency numerical classification. Choose what is convenient for your hospital and include a description in the written plan.

*Inventory. OSHA mandates an inventory of hazardous materials and waste on site.(2) The list must indicate work areas in which the chemicals are used. Once the list has been developed, MSDSes can be collected, labels designed, a training program formulated, personal protective equipment ordered, and emergency responses planned.(3) Some hazardous materials commonly found in and around various hospital departments are listed in Figure I.

Develop an inventory form that allows you to track all hazardous material in the hospital. The form should include the date; the name of the material, its components, and its EPA and MSDS numbers; the quantity of material, both in use and stored; the name of the department using it; the type of hazard (carcinogen, for example); and how the material is to be disposed of.

During the inventory phase, the hazardous material officer has the greatest opportunity to interact with all departments in the hospital. Guiding others through the new procedures will garner goodwill for the officer and the laboratory. Form a hazardous material team that includes representatives from departments with the largest hazardous inventories. Your new team will be useful as you tackle your next responsibility.

* Emergency plan. In formulating an emergency response plan, outline the special procedures required for hazardous material cleanup and document the availability of equipment for hazard containment.(4) Having team members available who have been trained to direct the action in case of emergency is essential. By learning about materials in each other's departments, members become able to fill in as hazardous material consultants if an emergency strikes when the safety coordinator is absent.

* Monitoring effectiveness. Your plan must provide for regular and ongoing review of the effectiveness of the laboratory's safety policies and procedures as they are carried out during day-to-day activities. Members of the hazardous material team can be recruited to monitor activities throughout the institution.

* Additional tasks. Your final responsibility will be to file reports with the EPA and the local fire department listing the quantities of hazardous materials and wastes stored on the premises. The agency is concerned about even small amounts of hazardous waste, which, if spilled or dumped on the ground, could seep into the earth and contaminate groundwater that supplies wells.

* More benefits. The information generated in a well-planned and implemented hazard communication program will allow your facility to make informed decisions about purchasing particular products or substituting less toxic for more toxic materials.(5) In conducting a chemical inventory, department heads can do some housekeeping and replace substitutable chemicals. The hazardous material officer can assist the hospital in saving money by encouraging the reduction of hazardous inventory. New hazardous material taxes are based on inventory quantities. The less inventory you report, the lower your tax bill will be.

Employees will be more effective participants in health and safety programs when they understand the nature of the hazardous material in their work areas. By coordinating information about chemical hazards to employees, the hazardous material officer helps to minimize the number of chemically related injuries and illnesses. One result is a safer and healthier environment for patients, employees, and the surrounding community.

Figure I

Some hazardous materials commonly found in hospital departments

Business office: Toner in photocopying machines. Central Services: Ethylene oxide, used widely as a sterilizing agent; suspected carcinogen and mutagen. Dialysis unit: Formaldehyde, glutaraldehyde, bleach, other cleaning and disinfecting solutions. Dietary/food service: Cleaning solutions such as concentrated detergents and grease-eaters. Housekeeping: Hazardous byproducts from incorrectly mixed cleaning agents. Toxic chlorine gas from bleach mixed with cleansers containing phosphoric acid. Laundry: Phenols and other toxins in some detergents and disinfecting agents. Maintenance: Paints, solvents, pesticides, lawn chemicals, plumbing, chemicals (drain openers), welding rods, lead-based solder, mercury, asbestos-containing insulation. Operating Room: Unvented anesthetic gases, ethylene oxide used in equipment sterilization, cleaning and disinfecting agents. Pathology laboratory: Formaldehyde (a carcinogen and mutagen), used as a tissue fixative. Other toxic chemicals: xylene, acids, bases, lead and uranium stains, propane gas. Pharmacy: Chemicals required in drug preparation, concentrated drug powders and solutions, neoplastic drugs (a family of chemically unrelated agents that inhibit the growth of tumors). Special risk to embryos and fetuses. Radiology: Reproductive harm from excessive exposure to x-rays and ultrasound equipment. Special risk to women of reproductive age from scattering of x-rays emitted by portable machines. (1)Lowengart, R.A., and Peters, J.M. Childhood leukemia and parents' occupational and home exposures. J. Natl. Cancer Inst. 19(1): 39-46, July 1987. (2)"Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small Business." Washington, D.C., Office of Solid Waste and Emergency Response, Environmental Protection Agency, September 1986. (3)"Hazardous Material Safety." Tucson, Ariz., Medfilms, Inc., 1987. (4)Garbo, M.J.; Comeau, N.A.; and Swanson, K.A. OSHA hazard communication standard. AAOHN J. 36(9): 366-371, September 1988. (5)Soloman, C.J. Understanding and using the MSDS. AAOHN J. 36(9): 376-379, September 1988.

PHOTO : The hazardous material officer informs the staff about workplace toxins.

Romaine McDonnell, M.S., MT (ASCP) The author is hazardous material officer and director of diagnostic services at Las Encinas Hospital, Pasadena, Calif.

In addition, make sure to read these articles:

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Interview with Dr. James McGlothlin, Associate Professor of Industrial Hygiene and Ergonomics, Purdue University