Dec 29, 1992 - OSHA's Hazard Communication Standard.Dec 29, 1992 - OSHA's Hazard Communication Standard.
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OSHA Hazard Communication Letters of Interpretation
ILPI assessment: Outside prescriptions do not create a blanket HazCom exemption
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). The written-program and employee-information principles remain useful. However, an outside physician or pharmacy is not itself an HCS exemption: once a nonexempt hazardous medication is known to be present with potential employee exposure, applicable duties must be addressed.
Hazard communication standard and pharmaceuticals() Coverage depends on hazards and applicable exemptions, and occasional crushing of a pill not normally dispensed that way differs from a drug designed for crushing or dissolving.
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Sara Prueitt of my staff contacted you to see if she could answer your questions over the telephone, however you requested written clarification for your files. You asked whether your long term health care facilities would fall under the scope of the Hazard Communication standard (HCS) in cases where your residents buy their medications from pharmacies that are independent from your facilities and which are prescribed to them by outside physicians.
The HCS applies to your staff of health professionals in many ways, as you have acknowledged. For example, Britthaven would have to inform employees of the hazards involved in using standard (i.e. foreseeable) medications used in practicing health care in your facility, such as the "house drugs" mentioned in your telephone conversation. However, in cases where the residents of your facilities purchase drugs from independent/outside pharmacies, and the drug and its potential hazards are not known until an outside physician orders a prescription, the HCS would not apply.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The outside source of a prescription is not a regulatory exemption. Apply current scope and current drug exemption to the actual known medication and potential staff exposure; maintain applicable program, access and training protections.]
The purpose of HCS is to communicate information concerning hazards and appropriate protective measures to employees. Employers must provide information to their employees about the hazardouschemicals to which they are exposed by means of a written hazard communication program. The hazard communication program must be developed, implemented and maintained at the workplace, and must also include a list of hazardouschemicals known to be present at the worksite.
Employees must be allowed to have access to information; therefore, if employees find themselves working with a medication brought in by a resident they may ask their employer to obtain a material safety data sheet for the medication. The HCS requires employers to provide information on "any chemical which is known to be in the workplace in such a manner that employees may be exposed..." (29 1910.1200(a) [ILPI:Original HCS 1987 context (PDF) · Current HCS]. Britthaven's facilities must incorporate their individual method of compliance into its existing HCS program.
Please find enclosed a copy of the OSHA booklet "Chemical Hazard Communication" which explains the standard and employers' responsibility under the rule. Under the Occupational Safety and Health Act of 1970, States are permitted to assume responsibility for their own occupational safety and health programs under a plan approved and closely monitored by Federal OSHA. The North Carolina Department of Labor operates under such a plan. As a condition of plan approval, States are required to adopt and enforce standards that are either identical to or "at least as effective" as the Federal standards. For information regarding the requirements of North Carolina standards, you may want to contact:
North Carolina Department of Labor 4 West Edenton Street Raleigh, North Carolina 27601
Telephone: (919) 733-7166
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Roger A. Clark, Director Directorate of Compliance Programs