Mastering OSHA 1910.1200 Compliance in Pharmaceutical Manufacturing: Your Essential Checklist

Ensuring compliance with OSHA's Hazard Communication Standard (HCS) under 29 CFR 1910.1200 is critical for pharmaceutical manufacturing. This checklist will guide you through the essentials to meet these requirements, ensuring your workplace remains safe and compliant.

1. Develop a Written Hazard Communication Program

Start by crafting a comprehensive written program. This document should outline your facility's methods for managing and communicating chemical hazards. Include procedures for labeling, safety data sheets (SDS), employee training, and non-routine tasks. Based on my experience, a well-documented plan not only aids compliance but also streamlines operations.

2. Inventory and Label All Hazardous Chemicals

Conduct a thorough inventory of all chemicals used in your facility. Each must be labeled with product identifier, signal word, hazard statement, precautionary statement, and pictograms. In my previous audits, I've seen facilities struggle with unlabeled chemicals, which can lead to serious compliance issues.

3. Maintain and Access Safety Data Sheets (SDS)

Ensure that an up-to-date SDS is available for each hazardous chemical. These should be readily accessible to employees during each work shift. We've found that digital solutions can significantly improve the ease of access and management of SDS.

4. Employee Training and Information

Train all employees on the HCS elements, including the specifics of your program. Training should cover how to detect chemical hazards, the physical and health hazards of chemicals, protective measures, and emergency procedures. Regular refresher courses are essential to keep safety top of mind.

5. Address Non-Routine Tasks and Multi-Employer Workplaces

Develop procedures for non-routine tasks involving hazardous chemicals. Also, if your facility involves contractors or other employers, ensure there's a system for sharing hazard information. From my experience, miscommunication in multi-employer settings is a common pitfall.

6. Regular Audits and Updates

Conduct regular audits of your HCS program to ensure ongoing compliance. This includes reviewing and updating your chemical inventory, SDS, labels, and training programs. Remember, OSHA regulations evolve, so staying updated is crucial.

By following this checklist, you'll not only meet OSHA 1910.1200 requirements but also foster a safer working environment in your pharmaceutical manufacturing operations. For additional resources, consider visiting the OSHA website or consulting with safety professionals who can offer tailored advice based on your specific needs.