Right-to-Know

The purpose of Vets First Choice Hazard Communication Program is to ensure VFC employees are effectively informed concerning workplace health and safety hazards, especially chemical hazards.

The written Hazard Communication program addresses chemicals known to be present in the workplace to which employees may be exposed under normal conditions of use or in a foreseeable emergency. The Vets First Choice Hazard Communication Program extends to all VFC employees.

Contacts

 Overall Program Management – o Jennifer O’Grady, Pharm D. [email protected] o Talia Janzen, Pharm D [email protected] o Bambi Ogren, Pharm D [email protected] o

References

 Hazardous Communication Standard (29 CFR 1910.1200)

Vets First Choice Safety Resources:

 Employee Training Under OSHA Right-to-Know Memo  Right-to-Know Policy  Hazard Communication Right-to-Know Booklet

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Employee Training Under OSHA

MEMORANDUM

TO: Employees at Vets First Choice

FROM: Vets First Choice

RE: Employee Training Under OSHA Right-To-Know

Vets First Choice is regulated under the federal "Hazard Communications Standard" or "OSHA Right- To-Know Law" as it is more commonly named. The objective of this law is to transmit information concerning the nature of chemical hazards that employees may be exposed to in their work environment and what measures they can take to protect themselves.

A key component of compliance is employee training. Vets First Choice is responsible for making sure every employee receives appropriate training. To meet these training requirements, each employee is to read the booklet, “Hazard Communication –Right-to-Know”. Right-To-Know training sessions are held yearly for individuals requiring additional training on the use of chemicals and Material Safety Data Sheets (MSDSs).

Employees will be asked to sign an acknowledgement that they have read the booklet “Hazard Communication Right-to-Know”. This acknowledgment will be kept in the employee’s personnel files.

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Right-To-Know Policy Introduction The Federal Occupational Safety and Health Administration (OSHA) 29 CFR 1910.1200 requires employers to provide information regarding hazardous chemicals to employees who may be exposed to such chemicals in the workplace. This policy and its accompanying procedures establish mechanisms to assure compliance with this regulation.

Policy A. Responsibility 1. Program coordination and audit functions shall be provided by Safety Officer when applicable. The Pharmacist-in-Charge will be responsible for the program coordination and audit functions when Safety Officer is unavailable. 2. Responsibilities of the pharmacy and other departments are as designated in specific sections of the policy. B. Hazardous Chemicals

A hazardous chemical shall mean any element, chemical compound, or mixture of elements and/or compounds which is a physical hazard as defined by OSHA Standard in 29 CFR Section 1910.1200(c) or a hazardous substance as defined by the OSHA Standard in 29 CFR Section 1910.1200(d)(3).

C. Employees and Students

This policy applies to employees, student interns, etc. who may be exposed to hazardous chemicals in the course of employment, or education through any route of entry (inhalation, ingestion, skin contact, or absorption, etc.) and includes potential (e.g., accidental or possible) exposure under normal operating conditions or unforeseeable emergencies. Personnel are not included unless their job performance routinely involves potential exposure to hazardous chemicals.

D. Exemptions

This policy does not apply to:

1. Any article which is formed to a specific shape or design during manufacturing and does not release or otherwise result in exposure to a hazardous chemical under normal conditions of use; 2. Products intended for human consumption; 3. Any food, food additive, color additive, drug or cosmetic, or distilled spirits, wines, or malt beverages; 4. Laboratory operations regulated by the OSHA Standard "Occupational Exposures to Hazardous Chemicals in Laboratories, 29 CFR Section 1910.1200. E. Material Safety Data Sheets

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1. Material Safety Data Sheets (MSDSs) are documents containing chemical hazard and safe handling information prepared in accordance with requirements of the OSHA Standard for such document. 2. The Company wide Shared Drive shall serve as the central repository for MSDSs. 3. The pharmacy department shall request from chemical manufacturers and distributors a MSDS for each hazardous chemical they have inventoried. 4. The pharmacy department shall maintain copies of MSDSs for each chemical they possess and have them available for review by employees or their designated representatives and students. 5. The pharmacy department shall bear the responsibility for providing MSDSs for a hazardous chemical distributed in or outside the company. 6. Employees who desire a copy of the MSDSs for hazardous chemicals to which they may be exposed should contact the Inventory specialist or their supervisor. MSDSs can be found in the MSDS binders located by the compounding lab and 0n the companywide drive. Most MSDSs can also be found on the manufacturer’s website. F. Labels

Existing labels on containers of hazardous chemicals shall not be defaced. When a hazardous chemical is transferred from the manufacturer's labeled container, the chemical users shall ensure that the new container is labeled using the Hazardous Materials Identification System (HMIS) labeling system.

G. Chemical Inventories 1. The pharmacy department shall compile and maintain a Chemical Inventory. 2. The Chemical Inventory shall be updated annually and more often if necessary. 3. The chemical inventory shall be readily available to employees and their representatives. New or newly assigned employees shall be made aware of the Chemical Inventory before working with hazardous chemicals or before working in an area containing hazardous chemicals. 4. Chemical Inventories shall be submitted to the Inventory Specialist in the format specified each year and whenever updated. 5. Chemical Inventories shall be retained by Direct Vet Marketing for 30 years. H. Emergency Information

Each year and whenever updated, the pharmacy department shall provide the name(s) and the telephone numbers of knowledgeable representatives who can be contacted in case of emergency.

I. Training

1. New employees receive appropriate safety and health information, education, and training during their initial assignment. This training includes information about hazardous materials and processes in the workplace through the use of printed materials and classroom instruction. 2. New employee safety and health training program begins upon hire by the personnel department and continues with on-site training by the new employee's department supervision.

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3. The pharmacy department shall develop employee training programs for specific chemicals in their department. 4. Each department where any employee may be exposed to hazardous chemicals under normal operating conditions or unforeseeable emergencies shall provide, at least annually, an education program for employees using hazardous chemicals. Additional information shall be provided whenever the potential for exposure to hazardous chemicals is altered or whenever new and significant information is received by the department concerning the hazard of a chemical. New or newly assigned employees shall be provided training before working with hazardous chemicals or before working in an area containing hazardous chemicals. Training shall be the responsibility of the supervisory staff. 5. Pharmacy interns will be provided with PPE if during the normal course of the clinical rotation, if he/she will be exposed to hazardous chemicals. 6. The training program shall include the following information, as appropriate: the location of the hazardous chemicals; information on interpreting labels and material safety data sheets and the relationship between these two methods of hazard communication; an explanation of the acute and chronic effects of the chemicals and instruction on their safe handling, including necessary protective equipment to be used and appropriate first aid treatment; and general safety instructions on handling, clean up procedures and disposal of hazardous chemicals. Generic training on classes of chemicals may be provided when numerous chemicals are involved.

J. Rights of Employees and Students

1. Employees and students who may be exposed to hazardous chemicals shall be informed of such exposures and shall have access to the Chemical Inventory and material safety data sheets for the hazardous chemicals. In addition, employees and students shall receive training on the hazards of the chemicals and on measures they can take to protect themselves from those hazards. 2. The pharmacy department shall provide, at no expense to employees, appropriate personal protective equipment to protect employees from exposures to hazardous chemicals. Students may be required to purchase routine personal protective equipment (e.g., eye protection, lab coats, etc.); however, the pharmacy department shall provide specialized personal protective equipment (e.g., respirator, face protection, gloves, barrier creams, etc.).

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Hazard Communication (Right- to-Know)

 The Hazard Communication Standard  All About Chemicals  Chemical Labels  Label Systems: Colors, Numbers, and Symbols  The material safety data sheet (MSDS)  MSDS Availability  Use the MSDS to Stay Safe  Chemical Identity  Physical Hazards  Physical and chemical characteristics  Reactivity  Health Hazards  Avoid chemical exposures  Precautions and Controls  Practice Chemical Safety  Use of Personal Protective Equipment  Be Prepared for Emergencies  HazCom Program Availability  Training

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The Hazard Communication Standard Chemicals play an important role in our lives, but they may also present many hazards. Chemicals are safe when handled properly, but if you’re not aware of their potential danger, you can put yourself and others at risk. You have a Right-To-Know what hazards you may encounter on the job and how to protect yourself from these hazards. That is why the Occupational Safety and Health Administration (OSHA) created the Hazard Communication Standard (HazCom).

All about Chemicals You have a right-to-know The HazCom Standard was developed to ensure that employers provide their employees with the following information:

 Hazardous chemicals they may be exposed to and why they are considered hazardous

 Ways to lessen chemical exposure

 Ways to reduce the risks when working with hazardous chemicals

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Remember: Chemicals are a part of modern life. We don’t want to give up their benefit; but, we have to know how to handle them safely and recognize their hazards.

Two types of chemical hazards:

1. Chemicals with physical hazards may be:

 Explosive. They can suddenly release pressure.

 Flammable. They can catch fire easily.

 Reactive. They can burn, explode, or release toxic vapor if exposed to other chemicals, heat, air, or water.

2. Chemicals with health hazards can range from minor to deadly.

They may be:

 Corrosive. They can burn or even destroy skin or eyes on contact.

 Toxic. They can cause illness or damage specific organs, such as the kidneys or lungs. In the worst instances, they can cause death.

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Chemical Labels Labels play an important role in hazard communication. OSHA requires chemical manufacturers to label every drum, cylinder, bag, or container that holds a hazardous chemical.

OSHA requires all labels include the following information:

 The identity of the chemical  The name and address of the chemical manufacturer or distributor

 Emergency phone numbers  Warnings about the chemical’s specific physical and health hazards  Signal words such as - DANGER, CAUTION, or WARNING  Procedures, protective clothing, and equipment needed to work safely with the chemical  First aid instructions  Special instructions concerning children.

Valuable information is found on labels. Always read the label before you move, handle, or open a chemical container.

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Label Systems: Colors, Numbers, and Symbols If you remove a chemical from its original container, you must label the new container with the same information required by OSHA utilizing one of the following label systems:

1. These words may give warnings about the chemical:

. Carcinogen (causes cancer) . Irritant (irritates the skin or eyes) . Corrosive (burns the skin or eyes)

2. Signal words may tell how dangerous the chemical is:

. DANGER = can cause immediate serious injury or death . WARNING = can cause moderate injury or death . CAUTION = can cause relatively minor injury

3. Labels can use color to show the type of hazard:

. RED = Fire Hazard . BLUE = Health Hazard . YELLOW = Reactivity Hazard . WHITE = Special hazard or protective equipment is required

 Numbers can be used along with colors to show the degree of a hazard:

 4 = Extreme hazard  3 = Serious hazard  2 = Moderate hazard  1 = Slight hazard  0 = Minimal hazard

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The Material Safety Data Sheet (MSDS) The MSDS is an important right-to-know tool. It contains detailed chemical and safety information. Each chemical in the workplace must have an MSDS that identifies:

 The chemical

 The chemical’s hazard or hazards

 The conditions that make it most hazardous

 How to protect yourself, other people, and the environment from its hazards

 What to do in an emergency involving the chemical.

MSDSs are written and distributed by the chemical manufacturers or importers. They are sent with the initial shipment of the chemical. The can also be found on most manufacturers websites.

MSDS Availability Copies of MSDSs should be available in your work area. If they are not, check with your supervisor. If an MSDS cannot be found for a chemical in your area, other resources should be used to obtain the MSDS:

 MSDSs are available on the World-Wide-Web (WWW).

 MSDSs for chemicals purchased through a drug wholesale distributor or manufacturer can be found on their website.

 MSDS can be found outside the compounding lab and on companywide drive in the pharmacy folder under MSDS.

Use the MSDS to Stay Safe An MSDS contains the information needed to work safely with a chemical. Review the following pages to become familiar with key terms found on a MSDS — and why they’re important.

Chemical Identity The MSDS tells you what the chemical is, including:

 Common and chemical names

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 Names of any hazardous ingredients  Name, address, and telephone number of the chemical manufacturer, importer, or other firm that provided the MSDS so additional information can be obtained or they can be contacted in an emergency.

Also found on the MSDS is a measure of how much of the chemical you can be exposed to without damaging your health. This may be:

 Permissible Exposure Limit (PEL), the maximum air contaminant a person can be exposed to on a repeated basis without developing adverse effects, as specified by OSHA regulations; or,

 Threshold Limit Value (TLV), the daily air concentration in which the American Conference of Governmental Industrial Hygienists (ACGIH) believes persons may be exposed to without adverse effect.

Physical Hazards The MSDS tells you if a chemical will:

 Catch fire  Explode  React dangerously if exposed to air, water, or other chemicals, and what conditions and substances to keep it away from.

Information alerting you to fire and explosion hazards may include:

 Flash point: Minimum temperature at which a flammable liquid's vapor could catch fire if it comes in contact with a spark or other ignition source. Lower numbers mean a greater fire hazard.  Upper and lower flammable or explosive limits (UFL, LFL, UEL, LEL): Minimum and maximum amounts of vapor in the air that could catch fire or explode if they contact an ignition source.

Physical and chemical characteristics The MSDS lists many chemical properties on how a chemical will behave under different conditions.

Normal appearance and odor: Characteristics helpful in recognizing the chemical. Boiling point: Temperature at which a liquid boils or changes to a vapor.

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Melting point/freezing point: Temperature at which a chemical changes from solid to liquid or liquid to solid. Solubility in water: How much of the chemical will dissolve in water. Specific gravity: A mass-to-volume comparison relative to water. (1). A specific gravity below 1 will float in water; above 1 will sink in water. Vapor density: Compares a chemical’s vapor density to air density. (1). A vapor density below 1 will rise in air; above 1 will sink in air. Vapor pressure: The higher the number, the faster a chemical evaporates, increasing inhalation risk.

Reactivity Identifies conditions that might cause dangerous chemical reactions.

Stability/Instability: Whether a chemical is prone or resistant to breakdown over time; conditions to avoid (heat, shock, pressure, etc.) to prevent hazardous reactions. Incompatibility: Specific chemicals, air, or water that could cause a dangerous reaction with the chemical. Hazardous decomposition products: Whether the chemical’s breakdown or reaction will create new hazardous products like toxic gases. Hazardous polymerization: Whether a chemical will react by itself, releasing heat that could lead to an explosion.

Health Hazards It’s very important to know what health problems could develop from exposure to a chemical. To help you understand the results of overexposure, the MSDS explains:

 Routes of chemical exposure (inhaling, swallowing, eye, or skin contact)  Type of exposure (acute or chronic)  Specific health effects from exposure (e.g., skin irritation or burns, breathing problems, reproductive problems)  Organs that might be affected (e.g., lungs or liver)  Whether the chemical may cause cancer (carcinogenic)  Signs and symptoms of exposure (e.g., headaches, nausea, dizziness, rashes).

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Avoid chemical exposures The MSDS also lists medical conditions that could be worsened by exposure to the chemical. If you have asthma, a heart condition, or any problem that’s listed on the MSDS, immediately alert your supervisor. You may need to take extra precautions to avoid contact with that chemical.

The MSDS also tells what to do if you are overexposed. First aid instructions to follow while waiting for medical help may include:

 Flushing eyes at an emergency eyewash station  Removing contaminated clothing and thoroughly washing skin  Getting to fresh air after inhaling a chemical.

Remember: If you work with chemicals, report any possible overexposure symptoms to your supervisor immediately!

Precautions and Controls An MSDS contains more than warnings. It has instructions and information on ways to reduce the risk of chemical accidents and health problems from exposure. It may cover:

 Personal protective equipment, such as respirators or eye protection  Hygiene practices, such as washing hands after working with the chemical  Engineering controls, such as ventilation  Instructions for handling and storing the substance properly and safely, such as avoiding heat sources.  Clean up spills and leaks  Put out fires  Dispose of the chemical properly.

Practice Chemical Safety Before you start any job, use the following safety checklist.

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 Look around for anything that could go wrong.

 Eliminate the risks before you start.

 Check and read labels and MSDSs.

 Use the correct protective clothing and equipment.

 Remove from the work space anything you could trip over or that creates a hazard — ignition sources, reactive chemicals, combustibles, etc.

 Be sure equipment is in good working order. If it’s not, DON’T USE IT. REPORT IT TO YOUR SUPERVISOR.

 Don’t eat or smoke in the work area.

 Use proper ventilation.

 Use the right tool or equipment for the job.

 Follow Standard Operating Procedures.

 Keep focused on what you are doing.

Use of Personal Protective Equipment Different chemicals and jobs require different levels of protection. Select equipment based on procedures established for your work area. You may have to wear:

 Safety glasses or goggles

 Protective clothing or suits

 Gloves

 Boots or shoes

 Respirators.

Be Prepared for Emergencies

 Know the location and how to use each piece of emergency equipment

 Know how to handle a small spill, leak, or fire

 Know your evacuation route and where to go in case of an emergency.

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HazCom Program Availability Vets First Choice employees may review the Hazard Communication Program at any time to ensure they are informed concerning workplace health and safety hazards, especially chemical hazards.

Copies of the program are available at the following locations:

 Company-wide (W:) drive

Training The training seminars are offered to personnel who work in the compounding lab and also non- laboratory personnel who work with chemicals. An individual should attend a training session if:

 they work with chemicals and have not been trained,

 the chemicals they work with have changed since their original training,

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APPENDIX:

CHEMICAL INVENTORY

Below is a list of the hazardous chemical(s) used or stored at this location. These chemicals are referenced to their appropriate MSDS's and are as follows:

Table 1 Drugs found in general pharmacy

DRUG Therapeutic NIOSH HD PPE Storage MSHG Classification Alkeran (Melphalan) Antineoplastic Agent Antineoplastic drug Gloves refrigerate yes (Preg Cat D) Ceenu (Lomustine) Antineoplastic Agent Antineoplastic drug Gloves yes (Preg Cat D) Chloramphenicol Chloramphenicols Non-antineoplastic Gloves (Viceton) (Preg Cat C) drug Cyclosporin Immunosuppressive Non-antineoplastic Gloves (Atopica) Agent (Preg Cat C) drug Cylcophosphamide Antineoplastic Agent Antineoplastic drug Gloves yes (Preg Cat D) Cytotec Antiulcerative, Non-antineoplastic Gloves (Misoprostol) cytoprotective agent drug -reproductive (Preg Cat X) Estradiol Estrogen (Preg Cat Non-antineoplastic Gloves X) Fluconazole, Azole-Antifungal Non-antineoplastic- Gloves Ketoconazole, (Preg Cat C) reproductive Itraconazole Griseofulvin Antifungal (Preg Cat Non-antineoplastic- Gloves X) reproductive Hydroxyurea Antineoplastic Agent Antineoplastic drug Gloves yes (Preg Cat D) Imuran Immunosuppressive Non-antineoplastic Gloves yes (Azathioprine) Agent (Preg Cat D) drug Kinavet-CA1 Antineoplastic Agent Antineoplastic drug Gloves yes (masitinib mesylate) (Preg Cat X) To avoid exposure to drug, wash hands with soap and water after administering. Leukeran Antineoplastic Agent Antineoplastic drug Gloves refrigerate yes (Chlorambucil) (Preg Cat D) Lupron, Leuprorelin GNRH (Preg Cat X) Antineoplastic drug Gloves yes (leuprolide) Lysodren (Mitotane) Antineoplastic Agent Antineoplastic drug Gloves yes (Preg Cat D) Megestol, Megace Progestin (Preg Cat Non-antineoplastic Gloves yes (Megestrol Acetate) X) drug Mestinon Anticholinesterase Gloves, Protective Eye (PYRIDOSTIGMINE Agent Wear BROMIDE ) tab & Sol’n Updated 03.10.2015 17 of 21

Methotrexate Antineoplastic Agent Antineoplastic drug yes (Trexall) (Preg Cat X) Palladia (Toceranib) Antineoplastic Agent Antineoplastic drug Gloves yes Paxil (Paroxetine ) SSRI (Preg Cat D) Non-antineoplastic Gloves drug -reproductive Premarin Estrogens (hormone) Non-antineoplastic Gloves (Estrogens, conjuated) Protopic Immunosuppressive Non-antineoplastic Gloves (Tacrolimus) Agent (Preg Cat C) drug Regu-mate Oral Progestogen for Non-Antineoplastic Gloves yes (Altrenogest) Horses drug-reproductive Spironolactone Anti- Non-antineoplastic Gloves (Aldactone) mineralocorticoid drug (Preg Cat C) Tamoxifen Estrogen Antineoplastic drug Gloves yes (Nolvadex) Agonist/Antagonist (Preg Cat D) Voriconazole Azoles (preg Cat D) non-antineoplastic Gloves drug - reproductive Zonegran Anticonvulsants (Preg non-antineoplastic Gloves (Zonisamide) Cat C) drug- reproductive

Table 2 hazardous drugs in Compounding Lab Hazardous Drugs in the Compounding Lab

Drug Therapeutic Effect PPE Cleaning/Neutralizing Classification Agent

Azathioprine immunosuppressant teratogen, carcinogen gloves, N95 respirator, water gown Chlorambucil antineoplastic carcinogen, teratogen, gloves, N95 respirator, eyes: medical attn skin: impaired fertility gown water and an emollient.

Chloramphenicol antimicrobial carcinogenic, harmful to gloves, N95 respirator, water fetus/newborn gown Colchicine anti-gout teratogen, impaired fertility gloves, N95 respirator, water gown Cyclophosphamide antineoplastic carcinogen, teratogen, gloves, N95 respirator, water impaired fertility gown Cyclosporine immunosuppressive carcinogen gloves, N95 respirator, water gown Fluconazole, antifungal respiratory hazard, feto- gloves, N95 respirator, water Ketoconazole, toxicity gown Metronidazole Griseofulvin antifungal teratogen, carcinogen, gloves, N95 respirator, water reproductive hazard gown

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Hyroxyurea antineoplastic mutagenic gloves, N95 respirator, water gown Lomustine antineoplastic carcinogenic, mutagenic, gloves, N95 respirator, water teratogenic, impaired fertility gown Megestrol Acetate estrogens carcinogen, impaired fertility gloves, N95 respirator, water gown Misoprostol Anti-ulcerative abortifacient gloves, N95 respirator, water gown Phenoxybenzamine Antihypertensive carcinogen gloves, N95 respirator, water (Preg Cat D) gown Spironolactone diuretic reproductive hazard gloves, N95 respirator, water gown Sulfasalazine anti-inflammatory reproductive hazard gloves, N95 respirator, water gown Vetoryl (trilostane) steroid blocker teratogen, imparied fertility gloves, N95 respirator, water gown Zonisamide anticonvulsant teratogenic gloves, N95 respirator, water gown

Drugs with potential reproductive hazards

Amitriptyline Antidepressant (Preg Reproductive hazard; Gloves, N95 water Cat C) May cause harm to respirator, gown breast-fed children. Budesonide Corticosteriod (Preg Suspected of Gloves, N95 water Cat B) damaging fertility or respirator, gown the unborn child- extremely high dose long term exposer. Pergolide Dopamine receptor May cause harm to Gloves, N95 water agonist (Preg Cat B) breastfed babies respirator, gown Reserpine Antihypertensive Reproductive hazard Gloves, N95 water (Preg Cat C) respirator, gown

Tables are also posted in the compounding lab and pharmacy.

Employees wishing to see these tables should contact their supervisor. Tables are also posted in the compounding lab and pharmacy.

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Statement of Acknowledgement of potential exposure to Hazardous Drugs

I, ______, have read Vets First Choice’s “Hazard Communication Right-to-Know” booklet. I have been provided with a current list of Hazardous Drugs found in the pharmacy as well as access to their MSDS sheet. I have received training on Personnel Protective Equipment available to employees. I am aware that a copy of this signed acknowledgment certifying that I understand the procedures will be kept in my personnel files.

My employer has informed me that exposure to Hazardous Drugs and non- hazardous drugs may exacerbate (worsen) certain health conditions and or allergies.

Employee Signature: ______Date: ______

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