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 Updated 03.10.2015 1 of 21 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. Updated 03.10.2015 2 of 21 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 Updated 03.10.2015 3 of 21 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. Updated 03.10.2015 4 of 21 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.). Updated 03.10.2015 5 of 21 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