Pharmacy implications of the revised OSHA Hazard Communication Standard

Provisions of the recently revised federal Occupational Safety and Health Administration (OSHA) Hazard Communication Standard that are important to pharmacy practice in organized health-care settings are described. OSHA announced on February 15, 1989, that the revision of August 24, 1987, was effective immediately; the provisions apparently pre-empt individual states' hazardous-substances regulations. According to the standard, manufacturers must determine whether chemicals they produce are hazardous; a pharmacy compounding drug mixtures may be a manufacturer. Chemicals determined by the manufacturers to be hazards must be labeled as hazards; for drugs that are already labeled according to FDA requirements, such labeling is not needed. The rule exempts drugs in a retail establishment that are packaged for sale to consumers, but it does not address workers' use of such non-prescription products in patient care. Tablets are exempt. Employers must maintain a written hazard communication program. Manufacturers and distributors are required to provide material safety data sheets on all hazardous chemicals, and employers must keep copies of these data sheets available. Documents to assist employers in complying with the regulations are available from OSHA. Judicial challenges to the regulation continue. ASHP is monitoring developments and applications to assist pharmacy departments in interpreting and complying with the regulations.