No OSHA Hazcom Training in Healthcare

The last two blog entries described a survey of low temperature sterilization and liquid sterilants and high level disinfectants. The survey was conducted at the recent IAHCSMM show where we invited attendees to complete a short information card in exchange for being entered into a competition to win some prizes.

We had about 175 respondents and eliminated entries that did not list the chemicals and equipment, and multiple people from the same institution. For this analysis non-US facilities were also excluded, leaving 117 US based facilities that use low temperature sterilization and in most cases liquid sterilants/high level disinfectants

The most startling answer we received on our survey was to the question “Have you ever received OSHA HAZCOM Training?” Of the 89 people who answered this question, 45 (51%) said YES and 44 (49%) said NO.

OSHA’s Hazard Communication (Hazcom) Standard 29 CFR 1910.1200 applies to any work location where chemicals are used and requires training about the chemicals used (safe use, how to recognize leaks, safety data sheets, and labels; and of course training about the standard itself.)

Our survey was shocking since it is a federal law that everyone who uses chemicals in the workplace be trained on the HazCom standard. The International Association of Healthcare Central Service Materiel Management (IAHCSMM) show is for primarily for people who work in sterile processing departments in healthcare. Additionally, all of the people included in this survey had identified the chemical used for low temperature sterilization and so presumably are working with or near potentially hazardous chemicals.

However, the percentage of people who have not had Hazcom training may be conservative. ChemDAQ’s President & CEO, David Hilliker, frequently gives talks about the HazCom standard to people from hospital sterile processing departments and he estimated that about 80% audience members that he talked to individually have never had HazCom training. Our survey was voluntary and perhaps a disproportionate fraction of the 28 people who did not answer this question in the survey would have selected NO had they checked a box. For information about ChemDAQ’s Hazcom training program contact Kevin Vaughn at

In 2009 the NIOSH-NORA State of the Sector Healthcare and Social Assistance report stated in the Executive Summary that

The HCSA sector is burdened by the historical and entrenched belief that patient care issues supersede the personal safety and health of workers and that it is acceptable for HCSA workers to have less than optimal protections against the risks of hazardous exposures or injuries.

If our survey is representative across healthcare in the US, then it suggests that healthcare can make significant improvement in workplace safety, at least with respect to exposure to hazardous chemicals, by improving training and ensuring at a minimum that everyone has the training they are required to receive by law.