Implementing a Hazardous Chemical Program
Review your state specific requirements for workplace and occupational safety regulations. There are many OSHA-approved state plans in lieu of Federal-OSHA regulations. The following guides and templates are only Federal-OSHA specific.
Requirements:
- OSHA requires every pharmacy to have a Hazard Communication Standard pursuant to the OSHA Hazard Communications Standard, 29 CFR 1910.1200.
- See Policy & Procedure: Haz-1: Hazard Communication Standard for a template.
- Additional considerations regarding the Hazard Communication Standard:
- Per 29 CFR 1910.1200: Drugs defined by the Federal Food, Drug, and Cosmetic Act that are in solid, final form for direct administration to the patient (e.g. tablets, pills), drugs which are packaged for sale to consumers in a retail establishment (over-the-counter drugs), and drugs intended for personal consumption by employees while in the workplace (e.g. first aid supplies) are exempt from the safety data sheet requirement.
- Per 29 CFR 1910.1200: Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposure that could reasonably be experienced by consumers when used for the purpose intended, are exempt from the safety data sheet (SDS) requirement.
- When creating the pharmacy Hazard Communication Standard, consider the risk of potential exposure to employees, including duration and frequency of exposure, to determine if those chemicals should be included in the standard.
- Review the following for additional references:
- Review the following for example SDS education, Standard Labels and Pictograms:
Best Practices:
- Consider implementing a hazardous drug occupational safety program which is meant to complement the Hazard Communication Standard.
- The Hazard Communication Standard is required to ensure chemical safety in the workplace. An occupational safety program outlines more general safety policies and procedures for a safe and healthy workplace.
- See Policy & Procedure: Haz-2: Hazardous Drug Occupational Safety Program for a template.
- Create a “Hazardous Drug Information” Binder with all required documents.
Policy & Procedure Template Implementation:
- Complete an initial review of each policy and procedure.
- Recommended staff that should complete an initial review:
- Pharmacy owner.
- Pharmacist in charge (if different).
- Compliance officer (if different).
- Pharmacy operations director (if applicable).
- Other lead staff deemed appropriate.
- After the initial review, make any necessary modifications to add state law and/or pharmacy specific policy and procedures. This step is critical to ensure the policy and procedures are specific to your pharmacy.
- Consider collaborating with an attorney for review.
- Add your pharmacy logos to the outline, policies and procedures, and other documents if needed.
- Complete the table at the top of each policy and procedure, indicating which staff member approved the policy and procedure, the initial date of approval, and the next review date to maintain compliance.
- Host a meeting to educate any additional pharmacy staff on the policies and procedures. If you adopt a policy and procedure, you MUST ensure all staff remain compliant with that policy and procedure.
- Ensure all pharmacy staff sign an acknowledgement attesting that they understand and agree to abide by the policies and procedures set forth. Review and renew the acknowledgement yearly.
- Review each policy and procedure at least yearly, as required with regulatory or pharmacy procedure(s) changes, and/or whenever deemed necessary.
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