There is often misunderstanding as to what OSHA regulates in a dental facility. OSHA, in fact, is concerned with only one thing—the safety of employees. OSHA, which is an acronym for the Occupational Safety and Health Administration, was formed through an act of Congress and its requirements are federal law. OSHA is concerned with all hazards that may be found in a dental office including those from the chemicals/materials we use daily.
The Globally Harmonized System for Hazard Communication
The newest OSHA regulation that is concerned with chemical safety is the Globally Harmonized System for Hazard Communication (GHS). The GHS, as the name implies, is a way of communicating chemical safety hazards in a consistent manner throughout the world.
This new system utilizes Safety Data Sheets (SDS) and labeling that will be identical for the same chemical no matter if it was manufactured in Europe, Asia or North America. This will not only enhance the protection of both people and the environment, but will facilitate international trade. For example—in the dental industry, many products come from the United States, Japan and Germany. Once GHS is fully enacted, health care workers will see the same type of product labels and SDS on all of the products they purchase—no matter what the country of origin.
OSHA has decided to do a gradual phase-in, which will make implementation of these new regulations much easier. The compliance dates are as follows:
1. Employers/End Users
- Currently-Train employees on new labels and SDS
- June 1, 2016 -Update labels, complete training and fully implement a GHS compliant hazard communication program
2. Chemical Manufacturers, distributors and importers
- June 1, 2015 – Must comply with all provisions of GHS but may still ship the inventory they still have under the old system
- December 1, 2015 – All products shipped must be follow GHS protocol
Now is the time for all dental offices to begin GHS implementation. Start by training your staff on its requirements and develop a plan for full implementation by June 1, 2016.
Deadline is 2016 not 2015 June 1st? Also DOES everything have to be labeled – small/larger even smaller :). Cost of labeling any suggestions ? Any in house labeling ? Such an expense !
Dental office labeling includes what? DO we have to label every hazard with a new GHS label?
Do we have to label secondary containers?
Hi Pat, you can refer to our reply below for more detailed information! We would suggest using only the new GHS compliant labels that are available from your Patterson Dental representative! Please let us know if we can clarify anything else. Thanks!
Hi Lu! Everything that is not in its original container (this would be called a secondary container) must be labelled. Since most items are still in their original containers with the manufacturers labels on them, this job is actually quite easy! This would normally mean that plaster/stone bins, cold sterile tubs, bottles of disinfectant, syringes of bleach, developer fixer containers, handpiece lube stations, tray cleaners, ultrasonic cleaners and instrument pre-soak tubs are all that need to be labelled. For small items like syringes of bleach, consider using “batch” labeling. This simply means that the tub, or cabinet shelf they are stored on/in is labelled rather than each individual item. These labels are available from your Patterson Dental representative.
What is batch labeling??
Does dental stone/plaster have to have a label because it is out of the original box ?
Since we have to keep MSDS/SDS sheets for 30 years do we have to keep the old ones and the new replacement sheet? Do you have a list of products that we have to have SDS for? A lot of questions I know.
I have a question about Sterilization, would stamping the sterilization pouches before sterilizing with the current date and writing with a permanent marker the no. of the autoclave be better, or should we stamp and label after sterilizing the pouches?
Hi Gregory! Thank you so much for stopping by OffTheCusp, and for reaching out with this question! It is recommended to stamp the pouches after sterilization! Here is some additional information from OSAP that dives into a bit more detail 🙂 https://www.osap.org/page/FAQIP20163/FAQ—Instrument-Processing—2016.htm