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Hazard Communication Program
A fill-in written hazard communication program for a small clinic: how you'll handle labels, safety data sheets and training, and the list of hazardous chemicals you keep, from disinfectants to peel solutions.
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Hazard Communication Program
MedSpaBinder
Clinic
Program coordinator (name, title)
Effective date
Required by 29 CFR 1910.1200(e) wherever staff may be exposed to hazardous chemicals. No small-employer exemption.
1. Labels
Who checks that incoming containers are labeled
How secondary containers (spray bottles) are labeled
2. Safety data sheets (SDS)
Where SDSs are kept (binder or online, reachable every shift)
Who gets and files the SDS for each new product
3. Training
Trained when: at hire, and when a new chemical hazard is introduced
Trainer (name, title)
Training records kept at
4. Non-routine tasks (e.g. cleaning up a chemical spill): how staff are told of the hazards
5. List of hazardous chemicals (use the product name on each SDS)
Approved by: ______________________ Date: ____________ Next review: ____________
Who needs a written hazard communication program?
Any employer whose employees may be exposed to hazardous chemicals at work. In a clinic that usually means disinfectants, alcohol-based preps, chemical peels and sterilizer chemicals. Consumer products used the way a consumer would use them, in similar amounts and frequency, are exempt, but most professional disinfectants and peels aren't used that way.
What OSHA requires
- A written program describing how you'll meet the requirements for labels, safety data sheets and training.
- A list of the hazardous chemicals known to be present, using the product identifier on each safety data sheet.
- How employees are told about the hazards of non-routine tasks.
- A safety data sheet for each hazardous chemical, readily accessible to employees during every shift. Electronic access is fine if nothing gets in the way of immediate access.
- Training at the time of initial assignment, and whenever a new chemical hazard is introduced into the work area.
How to fill it in
- Walk every room and write down each chemical product you find, then check you have its safety data sheet.
- Put the list and the safety data sheets in one binder or folder everyone knows about.
- Label spray bottles and other containers you fill yourself with the product name and its hazards.
- Add each new product to the list and the binder the day it arrives.
Questions
Can safety data sheets be kept online?
Yes. OSHA allows electronic access as long as there are no barriers to immediate access for employees in each workplace, during every shift. A tablet or computer that's always available works; a password only the manager knows doesn't.
How often is hazard communication training required?
At the time of initial assignment and whenever a new chemical hazard is introduced into the work area. There's no fixed annual requirement in the standard, but many clinics refresh it with their yearly bloodborne pathogens training.
Sources
General guidance, not legal or medical advice. Requirements vary by state; follow your medical director and product labels.