Standard Interpretations - Table of Contents
• Standard Number: 1910.1200

September 13, 1993

Ms. Jan Harris
441 South Lancaster-Hutchins Road
Lancaster, Texas 75146

Dear Ms. Harris:

This is in response to your inquiry of June 26, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

You requested clarification on OSHA's coverage of medical office or surgery center needs to have MSDSs on orally administered and injectable medications. OSHA published a notice in the Federal Register on February 15, 1989, to inform affected employers and employees that all provisions of the HCS would be in effect in all industries, including employers whose employees are exposed to Food and Drug Administration (FDA) regulated drugs that pose a hazard. If hazardous FDA-regulated drugs are administered by injection or orally, they would be covered by the HCS.

There are exemptions to the standard that may cover many of the products in your facility. The scope and application of HCS exempts drugs that are in solid final form, as per 29 CFR 1910.1200(b)(6)(viii). The final form exemption would also apply to tablets or pills that are occasionally crushed, if the pill or tablet is not designed to be dissolved or crushed prior to administration. Additionally, the HCS does not cover radioactivity or biological hazards, including pharmaceuticals that are radioactive or biological. If a chemical hazard is present in a container with a biological sample packed in a hazardous solvent, then the container would be subject to the requirements of the HCS for the hazardous chemical. OSHA encourages employers to go beyond the prescribed requirements of the standard, and recommends that all hazards be addressed in an employer's Hazard Communication Program.

The purpose of the HCS is to communicate information to employees concerning hazards of chemicals in the work place, and to