Dental practices must train employees on new hazardous chemical labeling

Federal OSHA’s final rule also requires hazard communication plans be updated
June 25, 2024
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Hazardous chemical labels on containers contain images. Fine print is in soft focus and not readable.
QUICK SUMMARY: A final rule issued by federal OSHA updates the Hazard Communication Standard by improving the number and quality of labels and safety data sheets. All dental practices that have hazardous chemicals in the workplace must train employees on the new labeling and update the practice’s hazard communication plan no later than July 2026.

A final rule issued by federal OSHA that takes effect July 19 largely affects product manufacturers and distributors of hazardous chemicals used in the workplace, but all dental practices that have hazardous chemicals in the workplace must comply with training and other requirements starting in July 2026.

The rule updates the Hazard Communication Standard to improve its effectiveness and reduce the incidences of chemical-related illnesses and injuries “by better informing employees about chemical hazards in the workplace,” OSHA writes. The updated standard will do this primarily by improving the number and quality of labels and safety data sheets.

The changes are intended not only to help workers respond more quickly in emergencies but to help ensure first responders receive critical hazard information on safety data sheets. Definitions of liquid, gas, combustible dust, physician or other licensed health care professional and other terms have been added or updated as have the instructions for the labeling and transportation of hazardous chemicals by manufacturers and distributors.

Employers must provide training on new labels, safety data sheets

To ensure employees are aware of the improved hazardous chemical labeling, dental practice owners and other employers must comply with training and communication requirements.

Employers must complete the following actions for hazardous substances by July 20, 2026, and by Jan. 19, 2028, for any (less common) hazardous mixtures.

  • Train employees on the new label elements containing newly identified physical, health and other hazards.
  • Update their hazard communication program.
  • Update, if applicable, any alternative workplace labeling.

During the transition period between the rule’s July 19 effective date and employers’ compliance deadlines, employers may comply with the updated Hazard Communication Standard, the previous (2012) standard or both.

OSHA’s Q-and-A provides additional background on the final rule.

Updating the practice’s hazard communication plan

All dental practices that have hazardous chemicals in the workplace are required by law to have a written hazard communication plan that, among other things, lists all hazardous substances in the workplace, identifies the person or people responsible for labeling hazardous substances and specifies employee training on hazardous substances.

New dentists who do not yet have a hazard communication plan in place can use CDA’s members-only Hazard Communication Plan with customizable sections for the individual practice’s hazardous substance inventory, training documentation and more.

CDA will remind dentists about their compliance obligations as the deadlines near. Members should watch the CDA newsroom and weekly member newsletter, Inside California Dentistry.

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