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Hazardous chemicals and employees' right to know; state and federal laws require that employers provide adequate information and training about hazardous chemicals in the workplace.

Hazardous chemicals and employees' right to know

Last January, we received a request for information about 3,500 potentially hazardous chemical compounds in our teaching hospital's clinical laboratory. New York State's right-to-know law required us to have that information ready in 72 hours.1

While this inquiry by a union representing laboratory and other hospital employees was highly unusual, it was valid. Under both national and state regulations, clinical laboratories are responsible for providing information about and protecting employees from hazardous substances at work. Our laboratory did not have all the data needed to keep employees well informed; therefore we were not fully complying with the regulations. We moved to correct this situation immediately.

At present, 36 states have right-to-know laws about hazards in the workplace. The New York State law explains why regulation is necessary: "Sometimes the tragic results of this exposure to toxic substances may not be realized for years or even generations. Because of this, it is consistent to impose upon employers a duty to give each employee notice as to known and suspected health hazards involved in their employment and place of employment, which may cause death or serious physical harm to the employee or members of the employee's family.'

Federally, the Occupational Safety and Health Administration has been regulating clinical lab safety under its general industry health standards, which set permissible exposure limits for about 400 air contaminants and, in a series of rules on individual substances, cover such practices as monitoring, medical surveillance, record keeping, and training.

A new OSHA standard--specifically for clinical, industrial, and academic labs--will require each facility to comply with existing exposure limits and to develop and institute a "chemical hygiene plan' that spells out procedures to protect workers from toxic materials. Final approval of this standard is expected in November.

For the most part, such regulations are valuable, although the definition of what is hazardous remains unclear. Many things not deemed hazardous by the Federal Government are considered so under state laws. The Manufacturing Chemists Association lists 72,000 chemicals, and our state law says all are potentially hazardous.

For example, sodium chloride solutions are deemed hazardous by New York State, although they pose no real threat in the laboratory, short of accidental drowning. Because legislators and regulators are not fully aware of chemical properties and toxicities, it might be worthwhile to have environmental chemists, toxicologists, and other experts try to define uniformly what is toxic and thus a risk for laboratory employees.

After the New York State law took effect in 1980, only one of our employees sought information about hazardous substances before the union's inquiry. Since that blanket request, however, two employees have asked for information, and we have been able to answer their questions about specific chemicals promptly and satisfactorily.

At the time, we did not have the written inventory of chemicals that the union asked for, nor did we have complete copies of Material Safety Data Sheets from chemical manufacturers. From a regulatory viewpoint, we were not providing adequate training about all of the potentially hazardous chemicals in our lab.

The union's request for information compelled us to study closely what our state's right-to-know law required.

Posted notice of right to know. A basic provision requires employers to post signs informing employees that they have a right to information regarding all toxic substances used in the workplace. We posted such a sign in 1980 when the law took effect.

Material Safety Data Sheets. Laboratory managers must maintain copies of all Material Safety Data Sheets from manufacturers for all chemicals, reagents, kits, and formulations purchased or prepared by the lab. An MSDS informs employees about the physical and health hazards of a specific chemical (see Figure I). Our lab had purchased a compendium of safety data sheets when the law went into effect, but this collection was already outdated by the time the union contacted us.

Laboratories should request safety data sheets for all compounds they order from a manufacturer. If an MSDS is unnecessary for a chemical, the manufacturer should inform the lab in writing. These sheets must be made readily available in the workplace for any interested employee to read them.

Knowing the peculiarities of your own state law is important. For example, if an employee requests an MSDS in New York, using a form we are required to furnish, this information must be provided within 72 hours or the employee can refuse to work with the chemical. But once an MSDS is provided--and if all the necessary safety gear is available--the employee must continue working with the chemical.

Training and education. An employer is responsible for providing adequate training and education, as well as outfitting the lab with any necessary protective equipment. Secretaries, glassware and computer staff, technologists, technicians, pathologists, and lab directors and managers all need annual training about work hazards. New employees should be trained before they come into contact with dangerous chemicals, as should anyone reassigned to another area of the lab.

Employees should learn methods and observations to detect the presence or release of hazardous chemicals in use; how to read and interpret an MSDS; the physical and health hazards of chemicals, including routes of entry into the body; the acute and chronic effects of chemical exposure; protective measures to guard against unwanted exposure; and first aid for accidental exposure. Supervisors and instructors should specify when to use such items as hoods, gloves, safety glasses, and lab coats.

It is laboratory management's responsibility to insure that every container of a hazardous chemical is labeled with the chemical name and possible hazards. This requirement extends to transfer containers. If a container holds a mixture, all chemicals in the mixture should appear on the label, again with hazards listed. For example, a mix of acetone and alcohol for decolorizing slides should be labeled "flammable.' Other hazard categories include "carcinogenic' and "corrosive.'

Chemical inventory. Each laboratory in New York State must develop and implement a written hazard communication program. The heart of this program is a current inventory of all hazardous chemicals in the laboratory. In addition to informing workers of hazards, the inventory is an efficient way to determine whether new supplies must be ordered or if a quantity of some chemical may be found in a different area of the lab. We support these guidelines for the chemical inventory:

1. It must be made available to all laboratory workers.

2. When cataloging, it is imperative to include all chemicals, including soaps, cleaning agents, tanks of gases, and common chemicals, such as saline solutions, mineral oil, and D-xylose.

3. The inventory should include all reagents made in-house.

4. The inventory should be recorded by area of the lab, preferably by room number where chemicals are used or stored. This makes it easier to match users with chemicals.

5. When the inventory is complete, data should be arranged in several ways: alphabetically, for rapid access to an individual chemical; by location, to match employees with chemicals they use; and by manufacturer, in order to obtain the necessary Material Safety Data Sheets. We encourage recording this information on a personal computer so your lab has a ready database.

Outside contractors. Laboratory management must also inform outside contractors about possible chemical hazards when they work in the lab. The easiest way is to provide the chemical inventory to a contractor. Written proof of this transaction should be filed in the lab by the safety officer.

While these provisions have not made a noticeable difference in our overall laboratory safety record, the right-to-know law has made some employees more aware of the hazards they could encounter and more willing to use protective equipment we provide.

A hospitalwide committee has been formed to insure compliance with the state regulations. Within our laboratory, that function is primarily supervised by the safety officer. He constantly goes through the laboratory for new chemicals, orders appropriate MSDSs, and updates the hazardous materials inventory. The safety officer listens to employee complaints about chemicals they may be exposed to, is responsible for providing any information employees want or need, and informs the laboratory director or manager of such communications.

Cooperation among laboratory management, hospital administration, those with direct responsibility for safety, and the staff is essential to bring a clinical laboratory in compliance with the law. And compliance means that the right to know is supported by the means of knowing.

1. New York State Right to Know Law, Chapter 551, Article 48, Sections 4800-4808, and Article 28, Sections 875-833. Law was passed June 26, 1980.

Table: Figure I What a Material Safety Data Sheet contains
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Copyright 1987 Gale, Cengage Learning. All rights reserved.

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Author:LeFever, David; Martin, Bettina G.
Publication:Medical Laboratory Observer
Date:Aug 1, 1987
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