I've heard the term HAZMAT. Does that apply to veterinary hospitals?

HAZMAT is an acronym that stands for "Hazardous Materials."  The acronym HAZMAT is usually used to describe "hazardous waste materials," however, it's often used (albeit incorrectly) to describe the required Hazardous Communication Plan (note: the acronym HazCom is the correct one to use when discussing hazardous chemicals in the workplace.)  A Hazardous Communication Plan is required of all businesses that utilize hazardous chemicals in the workplace - including veterinary practices.

What is involved in setting up a hazard chemical program for the hospital?

When your practice is inspected by OSHA, you can be sure they will want to evaluate the effectiveness of your Hazard Communication Program and they'll certainly begin with a review of the required plan. This plan is the hospital’s rules, policies and procedures to ensure that employees remain safe when they have to handle potentially hazardous materials. This plan must be written or it will not be valid.

The plan does not need to be elaborate, just informative. Most practices already have the elements of the plan in place (meaning a person who makes sure bottles get labeled and someone who keeps up on the SDS library) so it just takes writing down the details on paper.

Your written Hazard Communication plan should be comprehensive enough to address the particulars of everyday situations but simple enough to be understood.

• If you’re writing your own plan, be sure to address these issues either as an integral part of the HCS plan or as separate, individual plans.
  
  
• An introduction or explanation outlining the practice’s commitment to a safe & healthy workplace. This introduction should also identify the person to contact for more information about the plan.
  
  
• An explanation of the system(s) used to identify potentially hazardous materials. This usually entails the use of signs or labels. Whenever possible, it is best to include an example of the label or warning sign directly into the plan. Also include the name of the person who is directly responsible for ensuring all containers are properly labeled. Click here for more information on on labeling.
  
  
• An overview of the Safety Data Sheet (SDS) filing system. Identify the location where the SDSs are kept and the manner in which they are filed (e.g., alphabetical by product name). Also include the name or title of the person who is responsible for obtaining SDSs for new products, reviewing the sheets for completeness and generally keeping the library up-to-date. Click here for more information on maintaining your SDS library.
  
  
• Explain the procedure for getting information and training to employees. If your practice does not have a formal, written training program, then the HCS plan should include the frequency and timing of chemical safety training as well as identifying any video, audio or written materials that will be used in the training. Be sure to describe the objectives of the training program - exactly what each employee should understand and apply after the training is accomplished. The name or position of the person responsible for administering the training program should also be included.
  
  

• A list of hazardous materials known to be on the premises is mandatory. This list must be current and include only hazardous materials (e.g., a printout from the inventory program showing every item on hand is not acceptable). As with all the other items, inclusion of the name or position of the person responsible for the accuracy of the list is also necessary. (Click here for more information on determining the hazard potential of a chemical.)
  
  This list is not to identify quantities of each chemical, but merely a compilation of all the chemicals available - regardless of their quantity. It's common for a veterinary practice to have OVER TWO HUNDRED hazardous materials on the premises at any one time. Do not depend solely on purchasing records, as it is typical for "stray" materials to make their way into a hospital as samples or trial products. Remember to include cleaning and maintenance chemicals, laboratory products, injectable drugs and laboratory chemicals.
  
  Many practices have "stores" of products that they no longer use, but have not discarded. Remember, presence, not use, is the determining factor for inclusion on the list. Now may be a great time to clean off those high shelves in the storeroom!
  
  This may seem like a very time consuming procedure, but it really isn't that bad. The best way to do this is to start at the front of the clinic and go through each room writing down all the materials found in the room. Of course, the pharmacy, treatment room and storage area will take the most time, but in general this inventory can be completed in about four hours in most practices. If in doubt, include it; if later that product is determined to be not hazardous, it can easily be removed from the list. Type the list into a computer and use the "sort" feature to alphabetize the list. Duplicate entries can be easily spotted and deleted. The hazardous materials list is now complete.

 

Did You Know...?

The Hazard Communication Standard (HCS) was initially adopted in 1983 and only applied to manufacturing businesses.

Because of court rulings it was revised in 1987 to expand the scope of the regulation to cover all employers in the U.S., including veterinary practices.

Another revision in 1994 was mostly an update to definitions and clarifications.

The 2012 revision aligned the reulation to adopt the United Nations' Globally Harmonized Standard (GHS) of Chemical Hazard Determination.