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
#178 OSHA Updates the Hazard Communication Standard - Again
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Recently, OSHA updated the Hazard Communication Standard, which became effective July 19, 2024. What does this mean for your practice? While there will be changes to implement, there is still plenty of time to learn more and prepare. This episode reviews the compliance deadlines and key updates.
- Updated Hazard Communication Standard: https://www.osha.gov/sites/default/files/HCS_side-by-side.pdf
Welcome. I'm Leslie Cannon. I'm Mary Gavoni.
SPEAKER_00I'm Linda Harvey. I'm Olivia Wan, and together we are the Compliance Divas.
SPEAKER_03Welcome to the Compliance Divas Podcast. This is Linda Harvey and I will be your moderator for this episode. Today, the Divas are talking about the new hazard communication standard and the updates that went into effect earlier this year. So hold on to your hats and take a listen. The compliance divas bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to our podcast through your favorite podcast channel or on our website, thecompliancedivas.com. Any resources that we mentioned today can be found in the show notes. And we always welcome your questions to support at thecompliancedivas.com. And at the end of this podcast, please don't forget to scroll down and give us a rating or some feedback. We'd love to hear from you. Well, listeners, effective July 19, 2024, the new hazard communications standard revisions went into effect. What does that mean? It means that OSHA adopted revision seven of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals, known as GHS for short. So just to take us back a little history here, if you've been in dentistry a long time, you may remember back in 2012 that OSHA adopted GHS revision three. And at that time, the material safety data sheets were replaced with safety data sheets, and we begin to see pictograms on the original containers, on the safety data sheets, and on your secondary labels. So those are some things that have changed over the past 12 years with the hazard communication standard, but let's talk about what changed now and is there anything that we need to do? So, Mary, can you kick us off? What's actually changed with revision seven, please?
SPEAKER_02Absolutely, Linda. I think in reading the standard myself, which I don't recommend necessarily for all of our listeners to do, and the first thing I would do is say if you want a copy of the new standard, you can get it from the OSHA website, but don't print it. It's 300 plus pages. So just save an electronic copy. Much of the information is about clarification and making sure that warnings and definitions and those types of things are more clear than they were in the previous revision. And since some types of technology and some types of products have evolved over the last few years, then that's a good impetus for making sure that everything is as clear as it can be in the standard. And there may be new definitions to clarify what the standard intends to do in terms of protecting employees from chemical hazards. So in the um version seven of the Globally Harmonized Standard, there will be new hazard categories and classes for things like desensitized explosives, not necessarily products that we use in dentistry, but aerosols. We didn't have a hazard class before for aerosols, and we, of course, work with aerosols in dentistry. So, meaning some of our disinfecting products, some other types of products that we use, um spray adhesives or those types of things. So we will see those changes made and we'll see some new labeling requirements. And I think this is something that's really important for us to state right up front is that there isn't anything right now that end users, employers, employees, and dental practices need to do. Right now, what is happening with um enhancing definitions and adding hazard categories, that's happening at the manufacturer's end of these products. So then every manufacturer or importer or distributor of a product then will have to review the new standard, make sure that they meet all those standards, that they have the appropriate hazard classes listed with their product, and they will have to update labels on their products to incorporate the changes that are happening in the standard in the revision. And the last thing that they will be doing is providing new safety data sheets. Every product that's impacted by the new definitions and clarifications and requirements will have to have a new safety data sheet. Um, Leslie's going to talk about when we have to have those in a minute, but just know that you do not have to run out and get new safety data sheets now because they won't even be ready yet.
SPEAKER_03Perfect, Mary. Thank you for reminding our listeners. Let's not to panic. What we want to do during this podcast is give you a heads up that the changes are coming because the law went into effect back in July, but the employer deadlines haven't come. So we're going to talk about that in a minute. But one of the positive things that I noted about this, Mary, was that with the addition of new definitions and the clarification of existing definitions, I think it just gives a better overstanding of this of the standards. So when anybody does read it, whether it's our listeners or ourselves, that we really more clearly know what OSH is intending with this. And I want to mention a couple of things when you talked about some of the different products that could be impacted, like the aerosols. And I remember being at different offices over time where sometimes they have spray paints in their storage closets. They've either done a project in the office or they brought something in because they're going to do a different project for a funny event or something, they've got spray paints. And that storage closet from time to time has been the pump room or the electrical room. And then I tell you, in a heartbeat, every single time the fire marshal comes in behind him and catches them with things that can explode that are in the wrong storage area. So that's one way that we have to be safer in our practice and thinking of those. But Leslie, let's circle back to the standard and what changed. And what are some of the important deadlines that our listeners need to keep in mind, please?
SPEAKER_01Yeah, there are some important deadlines that really, first of all, as Mary had mentioned before, the first deadlines come up for the manufacturers, importers, and distributors. So January 19th, 2026, and if you think of that as just a year from January, the compliance updates related to substances must be completed. Now, I'm going to explain substances. There's a definition for substances. Substances are any single chemical that could pose a physical or health hazard. Examples that are common for us to recognize would include isopropyl alcohol and then perhaps sodium hypochloride or bleach. And then on July 19th of 2027, there's a compliance update for manufacturers, importers, and distributors related to mixtures. And the definition of mixtures is really a combination or a solution composed of two or more substances in which they do not react. So an example might be for us in surface disinfectants or cleaning solutions that we have. We want to make sure that we're going to understand that those are considered mixtures. They're not a single substance. Now, let's get back to how it's going to boil down for dental offices. Employers have an uh on the deadline of July 20th, 2026, to provide compliance updates related to substances to employees and make sure that all of the information is well understood. And then also on July, pardon me, on January 19th of 2028, uh to update compliance related to mixtures. And remember again, substances is a single chemical that could pose a physical or health hazard. And the mixture is a combination of two different uh chemicals or substances in which they don't react. So there's two different products together.
SPEAKER_03Thank you, Leslie. So as you pointed out, the deadlines for employers is kind of far out to some degree. So I'm going to ask our diva Olivia to can you go into that more detail, Olivia, with the deadlines for the employers and revisit those dates again and just what happens to happen at those time frames. And then also let's circle back and just talk about the basics requirements, the basic requirements of this standard, because we know the hazard communication standard, I think, is either the most cited OSHA standard with the most violations. So help us out, Olivia.
SPEAKER_00Sure. I I really think we should, you know, we're looking at these compliance deadline dates, and we have January 19, 2028, we have July 20, 2026, which I'll go into in just a minute. But Linda, I I think the emphasis should be right now is are you even in compliance for what we have in place? Because so often we're going on site and dental offices are missing their hazard communication plan, or it's outdated, they don't have a chemical list, an inventory of the chemicals in use. Secondary containers are not labeled or not labeled properly, such as having a blank pictogram on it, or they don't have the corresponding safety data sheets, or they're missing training. I've seen OSHA site because they didn't train specifically on the product that you're they're using, such as the surface disinfectant, the ultrasonic uh cleaning fluid, and so on. So I think that we have to look at, you know, what are we doing right now to be in compliance for what we have? And then in looking forward, Linda, January 19, 2028, we have to update the alternate workplace labeling, such as those secondary chemical uh labels on containers, secondary containers. We'll have to update all the Hazcom programs because it'll have to reflect all of this new content and provide training, which means we have to have proof of training. And then July 20th, 2026, alternate workplace labeling, update the Hazcom program, additional training, and let's not forget gathering those updated safety data sheets. That's going to be a huge task. So we're going to have to allocate the time to do that. We cannot rely on, oh, I could just find it on the web. It has to be a personalized collection that we make, whether we maintain it electronically or paper format, we're going to have to get all those updated safety data sheets. So that means we have to be vigilant, we have to check on a regular basis. And I can assure you, Linda, unless someone is assigned to do this, it's not going to get done. Also, for whoever's responsible in doing this task, they need to go to their boss, whether that's an office manager or a dentist, and say, hey, I'm going to have to block out some time on my schedule so I can work on this. So you can meet these deadlines, especially those chemical inventories. Those are time consuming to have to type them up. And I hate to see when people waste time handwriting them because then you have to redo the process each time. So it's best to have an electronic collection for that inventory. So, yes, Linda, deadlines are coming. We want to be vigilant now, get into compliance, and then earmark these dates on our calendars so we have time to work on the program.
SPEAKER_03That's perfect, Olivia. I think that was very practical because now our listeners can be aware of the deadlines that are coming, but most importantly, focused on what they're doing now to be sure they are even in compliance. Because we all know, all of us, Steve has talked about this on previous podcasts, that this is a challenge. You know, keeping up with the chemical inventory list and the safety data sheet binder, especially when they are paper versions, is an ongoing task. It's just like sterilization and it's an ongoing process. You process the instruments, they come out of the autoclay, you've sterilized, you use them, they go back for the process again. It's just a similar concept with compliance in any area, but especially with the safety data sheets and the chemical inventory list. So take time to get everything organized now because if you're not organized now, you won't know which sheets you need to look for and get the updates going forward. So with that in mind, please we ask you to share this podcast with the rest of your team members and your boss, your office manager and your doctor, so that way everybody can understand that some deadlines are coming, some updates are required. And as you begin to hear more about this as our first deadline approaches in July 2020 20th of 2026, you'll be ready and the compliance divas will be providing more information at that time. So until then, please remember that the compliance divas bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to this podcast through your favorite podcast channel or on our website, thecompliancedivas.com. The resources that we mentioned today, and especially a shortened version that we have of the before and after red line version of this law, if you want to read it, we'll put that in the show notes. And we invite you to submit any questions that you have to support at thecompliancedivas.com. And please don't forget to scroll down in your podcast app and leave us a review or leave us a comment. Until then, we look forward to seeing you next time.