The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
#162 What exactly is a Chemical Inventory List?
Use Left/Right to seek, Home/End to jump to start or end. Hold shift to jump forward or backward.
Chemical Inventory Lists are one of the most misunderstood requirements of OSHA's Hazard Communication List. Is your Chemical Inventory List compliant? Listen in as the Divas explain in more detail.
- Guidance for Hazard Determination: https://www.osha.gov/hazcom/ghd053107#documentation
- Haz Com Compliance Directives: https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-02-079.pdf
- Steps to an Effective Haz Com Program: https://www.osha.gov/sites/default/files/publications/OSHA3696.pdf
- Tennessee OSHA: https://www.tn.gov/content/dam/tn/workforce/documents/Employees/SafetyHealth/WhatToDoBookletGHS.pdf
Welcome. I'm Leslie Cannon. I'm Mary Gavoni.
SPEAKER_01I'm Linda Harvey. I'm Olivia Long, and together we are the Compliance Divas.
SPEAKER_02Welcome to the Compliance Divas Podcast. This is Linda Harvey, and I will be your moderator for this episode. As the Compliance Divas, we bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to the Compliance Divas Podcast through your favorite podcast channel or on our website, thecompliancedivas.com. Any resources that we mentioned today will be in our show notes. And we invite you at the end of the podcast to scroll down to the bottom and leave us a review. If you happen to have any questions, we welcome them at support at thecompliancedivas.com. Today we're going to be discussing one of what I think one of the most confusing, misunderstood parts of OSHA's hazard communication standard. And that is keeping a chemical inventory list. We are frequently asked questions by our clients and attendees at meetings, what this comprises. And there's just always a lot of misunderstanding, a lot of confusion. So let's make sure that your chemical inventory list is compliant today. And as you listen into the divas, well, we will explain more. Our diva, Mary Gavoni, was not able to join us today, but she wanted to be sure that we did be backtracked and talk about exactly what is the hazard communication standard and why do we have to follow it. So, Leslie, would you mind jumpstarting us and talking about that for a moment, please?
SPEAKER_00Well, that's uh something I'm very happy to talk about because this is something that I find uh is not mentioned at OSHA courses, and it's not mentioned uh I don't see any courses at major dental meetings covering the hazard communication standard. And the hazard communication standard was actually first adopted in 1983, and its scope expanded in 1987 to cover all industries where employees are potentially exposed to hazardous chemicals. So this standard is important because according to OSHA, over 43 million workers who produce or handle chemicals that are hazardous in more than 5 million workplaces across the country are exposed. And this is a number that's expected to go up as time goes on. The hazard communication standard is intended to ensure that exposed workers and their employers are informed of the identities of hazardous chemicals, the associated health and safety hazards, and the appropriate protective measures. So enforcement has something to quite a bit to do with uh why we see some citations on the hazardous communication standard as more frequently than any of the others, except for blood-borne pathogen standards. So, what has to happen is that employers have to protect employees by at minimum discussing topics that include the hazard communication standard and its requirements, the components of hazard communication program in the employee's actual workplace, uh, operations and work areas where the hazardous chemicals are present, and where the employer will keep the written hazard evaluation procedures, communication program, and lists of hazardous chemicals, which is that chemical inventory list, the focus of our program today. Many of us know that uh uh MSDS's uh now material safety data sheets, that it that's been shortened to the word SDS or how can I SDS for safety data sheets. And so when employers are responsible for the safety of employees, that training has to include how the hazard communication program is implemented in that workplace, how to read and interpret uh information on labels and the safety data sheet, and how employees can obtain and use the available uh hazard information. They also need to know about the hazards of the chemicals in their work area, measures employers can take to protect themselves, or pardon me, employees can take to protect themselves from the hazards, and specific procedures put into effect by the employer to provide protection such as engineering controls, work practices, and the use of personal protective equipment PPE. They also need to do uh a little bit of uh training on methods and observations such as a visual appearance or smell. So you employees can use this training to understand when there's the presence of a chemical that they might be exposed to by sight or by smell. Linda?
SPEAKER_02Thank you, Leslie. I think I would tend to agree that when you think about the different meetings and seminars when there are OSHA presentations, they may or may not mention much about the hazard communication standard depending on how much time is allotted for that program. And the bloodborne pathogen standard tends to come to the forefront because it is so interwoven with infection control and prevention. And you just don't see as much emphasis on it. But still, the OSHA fines apply here as well. As we know, here in 2024, they are over, the federal fines are over $16,000 per day per violation for a serious um offense. Let's call in our diva, Olivia. If you could tell us, Olivia, a little bit more about what exactly is this chemical inventory list, what has to be on it, and why do you think everybody's so confused about it?
SPEAKER_01Sure, Linda. It's actually a list or an inventory of all the hazardous chemicals that are used in the dental office, and it is a required component of our hazard communication program. And as I'm sure all the divas would agree, it's probably an area that is most neglected when we are assessing compliance in the individual practices. They may have some of their safety data sheets, but nine times out of ten, they may be missing this critical component, which is the list or the inventory. And I've actually seen clients cited over this for not having it in place. And so basically, we have to maintain a list of the hazardous chemicals that are being used in the dental office, and we have to use the product identifier, which is the product name or the chemical name, and prepare the list in a format that's complies with OSHA. Uh, and so it takes time to build these lists, and I think what gets confusing, Linda, is that sometimes they feel like if they have their safety data sheets that they have fulfilled the requirement, but that's not enough. So whether you call it a list, an inventory, or an index, that's a required component uh in putting it together and satisfying the law. And so there's different ways that people compile their safety data sheets, which may lead to the confusion. For example, if they are compiling PDFs, that they're just downloading PDFs from the manufacturer's website or the the wherever they purchase supplies, and they download the PDFs, that's great, but they still have to prepare this list or inventory. Or it may be that they compile paper copies. And if that's the case, they still need to do the inventory. If they're using a computer program, such as a software application, that process is much easier because they can actually export the data to a spreadsheet that will uh populate these required columns of information that we have to maintain on file. But it's important to note that when we build these inventories, we have to build it based on what's present in the dental office, not just what we buy from one supplier. So all of us have our favorite group that we order from, and we may have several that we order other items that we can't get from our main supplier. So we don't want to leave off items from that inventory. And another thing I wanted to mention, Linda, that's citable is that if they're changing up brands, you know, if they're going with different brands, it may have different chemical components. So we have to have the exact safety data sheet that corresponds with that product and then have it listed on our inventory. So if we're shopping the deals, so to speak, then that inventory becomes very challenging to keep up with. And I would say, hands down, it's probably harder to build the inventory than it is to gather all the sheets.
SPEAKER_02I think I would agree with you, Olivia. It's harder to build the inventory than it is to collect the sheets. And I believe it is one of the most neglected areas of compliance in a dental office.
SPEAKER_01Other thoughts that you might have, Olivia? I also wanted to mention that I forgot just a second ago, Linda, is that in Tennessee, where I work as a consultant and practice, there are special requirements. So when you're building your inventory, and we'll list this in the show notes, Tennessee has some specific requirements in putting that form together. And so if you access the what to do booklet, which is a template for compliance for the hazard communication standard, it also references Tennessee's state-specific, the Tennessee Hazardous Chemical Right to Know Law, they provide appendix D and it gives you a sample workplace chemical list form. So not only do you have to maintain your inventory, you are required to maintain the employer's name on the form, mailing address, the individual workplace location, identification, county, type of business, federal employer ID number, and the uh SIC code, and how many employees. And that's in addition to your actual inventory. So there's quite a bit of compilation of information in putting these sheets together.
SPEAKER_02Olivia, I'm so glad that you mentioned that, and that will really help our Tennessee listeners. And I'll take a moment and compare it to the federal law. And Leslie being our Cal OSHA expert, she may have some input on anything different from California. But one of the items that we're putting in the show notes today is a clarification from the Federal OSHA website that lists these three, pardon me, these six items that need to be on a chemical inventory list. That's the chemical name, the CAS number, which is the chemical abstract system, the common name, any synonyms, the product mixture, if applicable, and then the percentage of ingredients in the product. So most products have more than one chemical, for example. Is one product is one of the ingredients 50%, 75%, or 5%? And I really like the fact, Olivia, that on top of these six things, the header that you mentioned for Tennessee is just great information to have anyway on the top of any header. I think that's a good idea to have office-specific information, including the standard industry, industrial code, and everything. It makes it easy and clean and very, very thorough. So I just wanted to reiterate then for a minute that briefly your chemical inventory list is an inventory of your chemicals in each product that you have. It's not a list of the products that you're buying from any of your suppliers. And the chemical inventory list does correspond or correlate to your safety data sheet collection because the information for the inventory is taken from those sheets, but it is different. And then I just want to remind everybody as well that your favorite supplier or suppliers, by law, has to make the SDS sheets available to you. So you can download it from any of their websites, you know, when you buy products from them, the chemicals, to help augment and grow and keep your SDS binder up to date. But please know that information that resides on their website and their ordering in their inventory for you all, their product catalog, so to speak, that fulfills their obligation to be compliant by making the sheets available to you, who's the end user. It does not fill your obligation to have your own safety data sheet binder and your own office-specific chemical inventory list. And as we've seen, there's been a lot of fines in these areas, and that dentistry is one of the top areas where we're being cited as well in violations. Leslie, do you have anything that you could give us any tips perhaps from Cal OSHA?
SPEAKER_00Well, I can tell you that uh in general, a federal OSHA as well as CalOSHA is that you periodically go through your safety data sheets. You can weed out for products that you're no longer using, but do keep in mind whether it's CalOSHA or Federal OSHA, the safety data sheet may be part of the employee's medical record. So how long do we keep the safety data sheets? Well, we can archive them for duration of employment plus 30 years, just like medical records. And that way, in the event an employee has had a reaction or adverse health effects due to exposure to a chemical, the employer can demonstrate that they had the safety data sheet that was used at that time with the information, whether it was an MSDS sheet or an SDS sheet. The other thing is that going through your safety data sheet book will help you in seeing what you're missing from your chemical inventory list. Going through your shelves will help you see what you're missing for safety data sheets and the chemical inventory list. And I realize that's an overwhelming task, but we do have sometimes counseled appointments or admin days in a dental office or in-service days where we have time to do this type of work. And uh I'm certain that putting an initial that you reviewed your chemical inventory list and a date, and uh also that you've reviewed your safety data sheets would certainly prevent a OSHA citation if you missed a few parts or a few pieces of what you were supposed to have.
SPEAKER_02Thank you, Leslie. I would like to point out that during the OSHA inspectors inspections where I've been on site, I the inspectors compare what's on your chemical inventory list to your safety data sheet binder. And the requirement for them to do so is listed in what's called the OSHA compliance directives. And OSHA has written directives to their investigators or their auditors and every single one of their standards. So there's compliance directives for the hazard communication standard, the bloodborne pathogen standard, so forth. And it does tell the inspector to double check between the chemical inventory list and the safety data sheet to make sure the information is listed. Let's talk about now how we can help our listeners to keep up with this throughout the year, you know, whether it's at a team meeting on an annual basis and everybody takes a few sheets and reviews the safety data sheets, cross-compares to what's on the chemical inventory list. Maybe you use a service to help you, maybe you hire a consultant. One way that I've told teams many times they're if they're keeping a paper binder for their SDS sheets, is that this binder is alphabetized. So it makes it very easy to go through and divide up the tabs, and each team member takes a few tabs, review the sheets for currency, take out the sheets that are outdated or no longer the products no longer used, and then archive it as you mentioned, Leslie. And then go back and look at your chemical inventory list to be sure that those information is on the list that should be there. Now we do have some listeners that may be using an electronic binder. Leslie, what are your thoughts?
SPEAKER_00Well, I also want to encourage everybody to really heed Olivia's advice to put this list on an Excel program because if you acquire a product and it's you maybe named uh something with a letter B and you don't have any spaces, you're handwriting it, then you're gonna have to continually write your rewrite your handwriting. So an Excel spreadsheet helps you to be able to add a line in so you can keep the names of the products or the components of it in alphabetical order.
SPEAKER_02That's a great idea, Leslie. Now, and we do know that the hazard communication standard says this information has to be readily available and up to date. So readily available means that it cannot be behind a password-protected program, such as when you log in to your favorite supply company to place an order. That's behind your password-protected environment and it's not readily available to the end users, only to the individual who's logging into that account. If you keep it with a service, please be sure that it's not password protected either. I know many times over teams will say, but we'll put the password on every computer, we'll make sure that everybody can log in. But to me, it's just one more step for someone to have to go through in an emergency. And I always caution teams because when an emergency occurs, meaning it somebody has a splash in the eye, that you're not looking it up for yourself. You're looking it up for a team member. And so the more quickly you're able to do so and be prepared for any kind of emergency, just like we're ready for a fire emergency, medical evacuation, all these different things that arise, you want to be ready to handle this kind of emergency as well. So it should not be behind a password-protected document. Many times over, it should not be on your server because if your server's down and you're still seeing patients, which is possible because maybe IT is there doing some updates and you have an issue happen, then again, it's not readily available. So there's different options we can look at. And Olivia, I bet you have some ideas that you could share.
SPEAKER_01I just wanted to supplement maybe a contrary thought that in working with some larger, large groups as well, they are using an online program that requires a login and password. And so we added, you know, they had posters throughout the facility. And on the poster, we wrote the login and the password because it's not governed by HIPAA, it's not protected health information. So the login and the password was on those posters, plus all of the workstations uh had it memorized. So just to supplement and make that process easy, uh, the signage had that information on it. So that might be a tip in case all else fails.
SPEAKER_02And that certainly is another way to approach it. That's certainly very reasonable as well. And I've seen one of the online companies that we typically use creates a poster for their customers with a QR code on it that goes right to their library right away, which is nice because then if the if the power's down and they can't get to the internet on their computer, there's always a tablet or cell phone that certainly can. So there's many ways that we can be compliant with this. So we hope that today's session has provided some clarity for you all on how to keep a chemical inventory list, what's supposed to be on the chemical inventory list, and some tips on some ways that you can approach developing and maintaining your chemical inventory list. As a compliance divas, we bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to the Compliance Divas podcast through your favorite podcast channel or on our website, the compliancedivas.com. All the resources that we mentioned today will be found in the show notes, and we invite you to scroll down and leave us a review. And importantly, if you still have questions about chemical inventory lists, drop us a question at support at the compliancedivas.com. We look forward to seeing you next time.