Infection is risky business, but some of the control measures used to prevent infection have risks of their own. Take glutaraldehyde, for example. Glutaraldehyde is a toxic chemical used to disinfect heat-sensitive medical, surgical, and dental equipment. It’s also used as a tissue fixative in histology and pathology laboratories and as a hardening agent in the development of x-rays; so, it can be found at several locations in many healthcare facilities. An accidental spill of glutaraldehyde could result in serious short- and long-term effects for workers in the area.1 Need for treatment would be urgent. With no time to waste, workers need to be armed in advance with knowledge about what to do in the event of a chemical spill.

OSHA mandates MSDSs
One of the ways the Occupational Safety and Health Administration (OSHA) protects workers from injury by chemical hazards is by requiring manufacturers or importers to develop a material safety data sheet (MSDS) for each hazardous chemical they make or import. The MSDS must accompany the initial shipment, or be sent to the distributor or employer prior to or at the time of shipment, and be re-sent with the first shipment after an MSDS is updated. If the manufacturer or importer fails to do this, the recipient is obligated to ask them for it.

OSHA requires the manufacturer or importer to post specific information on the MSDS, including but not limited to its chemical(s) and common name(s); its physical and chemical characteristics; any associated health hazards; its primary route(s) of entry; permissible exposure limits; engineering controls, work practices, or personal protective equipment needed; precautions for safe handling; date the MSDS was prepared or last changed; and contact information for the chemical manufacturer, importer, employer, or anyone else who can provide more information in the event of an emergency involving that particular hazardous chemical.2 "If you pour a substance into a smaller container, the new container label must exactly match the MSDS," noted Russ McCann, President, Actio Corporation, Hampton, New Hampshire.

MSDS Solutions

Highlighting the importance of MSDSs in worker safety, Mario Bottone, vice president, sales and marketing, MSDS Solutions, located at its branch in Montreal, Quebec, Canada, described MSDSs as "the user manual for handling hazardous materials." McCann added: "The MSDS is the backbone of a chemical management system and the first line of defense against chemical spills. They’re the first piece of information handed to emergency responders."

At the ready
To be in compliance with OSHA and the Joint Commission on Accreditation for Healthcare Organizations (JCAHO), employers must maintain copies of the MSDS for each hazardous chemical at the workplace. Employers are obligated to ensure that the MSDSs are readily accessible during all work shifts to all employees who work in the vicinity of the chemical. "Immediate access could mean on the web, in binders, on CD-ROMs or DVDs, or a paper-based system," explained McCann.

Robert Toreki, PhD, President, Interactive Learning Paradigms Inc, (ILPI), Lexington, KY, noted, "Employees should be able to produce a hard copy of the MSDS in their workplace without asking for help to retrieve it. No one should have to ask their employer for a key to a filing cabinet, for instance. If OSHA inspectors were to come and say to your employee, ‘Oh, you’re working with this chemical, can you show me the MSDS for it?’ the employee needs to be able to produce it on his own without coaching from anyone else. It should be printed or capable of being printed by those who may need it, such as the emergency department or firemen."

Consequences for noncompliance
Noncompliance in having MSDSs readily accessible is not an option. "Compliance is mandatory. JCAHO audits for compliance. You can lose your JCAHO accreditation, and you’re out of business," McCann flatly stated.

Noncompliance can have other consequences as well. Bottone advised HPN: "OSHA can fine you. Fines can range from $7,500 up to the six-figure range if you’re a repeat offender. There are a lot of cascading effects to noncompliance. There are worker compensation claims when people get injured because they don’t have access to the right information; worker compensation rates can go up; there’s missed time by employees."

Bottone added: "OSHA doesn’t have tons of inspectors walking the floors of facilities, but they do come, and if they find you in violation, they’ll put your name up on the OSHA web site, highlighting the fact that you haven’t taken your responsibility very seriously. Remember: If you are in the employee health and safety game, that is your job. Shouldn’t you be doing everything you can to ensure the safest environment for your employees?"

Toreki concurred: "There’s always the specter of an OSHA citation at any time. Not many facilities are visited by OSHA, but if they are visited and OSHA finds missing MSDSs, there will be a fine for the violation. If employers are willfully or deliberately lax with MSDSs, and there was an emergency where an MSDS was needed and it wasn’t available, the facility could be setting itself up for a huge legal liability because they’re not complying with the law. If they aren’t properly training employees, they’ll also set themselves up for legal liability."

"People see OSHA as the enemy when it comes to MSDSs," observed Toreki. "They tend to feel that MSDSs are written by lawyers to cover their butts; but, OSHA is interested in worker safety. The rules aren’t as complicated as people think; actually, they’re very simple, but you need to be informed. Our web site can be a valuable tool to help workers work safely, to reduce workplace injury, and of course to lower liability."

Managing MSDSs
In larger facilities, managing MSDSs can eat up valuable employee time. There are a number of products and services on the market that can streamline the process and save money at the same time. True, smaller facilities may need only a binder and an employee appointed to be responsible for making copies of the MSDSs accessible and updated; larger facilities may find the manual method not only inefficient but costly. Some facilities realize significant savings by using other options, such as internet subscriptions or data bases managed by someone else, but it’s not always an easy sell to higher management.

Bottone said, "Our biggest challenge is that we’re selling a solution many of our customers are seeing for the first time. They haven’t utilized this kind of solution in this kind of context before. People in this industry sometimes have a hard time selling this application to those in higher levels of management because they don’t understand the frustration that lower-management people, coordinators, and project managers deal with on a day-to-day basis in trying to keep MSDSs current. Our [system] really makes a difference. The way to get it sold to upper-level management is to put a strong emphasis on understanding the direct and indirect costs of managing documents."

Counting the cost
Do you know how much it costs your facility to have a warm body managing MSDSs in your facility? Here’s some help. MSDS Solutions has a calculator to help you figure out the annual cost of managing MSDSs manually (http://www.msds.com/index.asp). Their calculator also can be accessed from ILPI’s web site: (http://www.ilpi.com/msds/faq/
partd.html#expense).

The costs of managing MSDSs manually may be higher than you’d imagine. McCann told HPN: "In a very efficient corporate environment, the cost of managing MSDSs can range from $40 to $60 per MSDS per year. A hospital may use 1,500 MSDSs. Actio manages MSDSs for $10 or less per document. We give immediate cost savings, the MSDSs are always updated, and the hospitals know they are compliant. In essence, we’re freeing up a person at the hospital to work on healthcare versus shuffling paper. That’s the bottom line. Further costs can be saved if the hospital is part of a buying consortium. We’re one of the Premier business partners. A hospital can get a group buying rate at very low cost, less than $10 per document. It’s based on a per-hospital versus a per-MSDS basis."

Bottone suggested, "If our system replaces someone with an employee safety and health background who has been chained to a desk looking through piles of documents to update MSDSs, they can be freed to do other things, training programs for example. This individual can do more than chase documents. Productivity is enhanced. Think of the time involved from a salaried employee’s perspective. Updating 1,000 documents individually can take months of work. Because we are providing a model by which we do this from a one-to-many perspective, we are able to pass down those cost-savings to our customers. With MSDS Solutions, you can expect a 4- to 5-month payback on average."

Bottone pointed out another money-saving advantage offered by MSDS Solutions: "You’re able to consolidate what you have in terms of hazardous chemicals. Our solution acts as a business intelligence tool. You’re able to consolidate purchases and save money as well. It’s definitely not just an operational expense."

Which system is right for your facility? Toreki advised, "Cost varies depending on the size of the institution and competency of the safety people. Certainly some organizations can save time and money by going with data-based products or by going with an internet-subscription product. The data-based products are usually more cost-effective than the service products. It pays to shop around."

Safety saves money
Another aspect of saving cost is improving worker performance. Toreki opined, "Informed employees are less likely to have an accident by mixing incompatible chemicals, for instance; they’re more in tune with regulations and dangers of the materials they work with. Improved worker performance and safety is a benefit of a proper MSDS program." Toreki added: "We’re almost evangelical about helping people improve worker safety."

What’s coming?
Changes are in the air. McCann suggested we look for "more supply chain integration. Managing MSDSs should be hooked to the purchasing function, so that when the request is made to buy the chemical, you know the MSDS is online and available for the workforce. That’s a much more efficient approach than MSDSs being delivered with the packaging, having the guy on the loading dock take them out and deliver them to the administrator who makes the copies, punches holes in them, and puts them in the binders."

Also on the horizon are consolidation of some of the companies, predicted Toreki. Bottone concurred: "Certain companies will look at purchasing others."

REFERENCES

1.U.S. Department of Labor, Occupational Safety and Health Administration. Hospital eTool, HealthCare Wide Hazards Module. Glutaraldehyde. www.osha.gov/SLTC/etools/
hospital/hazards/glutaraldehy
de/glut.html.

2.U.S. Department of Labor, Occupational Safety and Health Administration. The OSHA hazard communication standard. Subpart Z, toxic and hazardous substances, 29 CFR 1910.1200. www.osha.gov/pls/oshaweb/owadisp
.show_document?p_table=STANDARDS
&p_id=10099.