It’s Your Call October 2017

OSHA:  Secondary Labels

Is our office required to use GHS labeling on secondary labels?

Yes, GHS labeling is required on secondary labels. There are two options for secondary/workplace labels. OSHA regulation 1910.1200(f)(6) states that each container should be labeled, tagged, or marked with either:

Option 1:  Product identifier, signal word, hazard statement(s), pictogram(s), and precautionary statement(s).

Option 2:  Some combination of product identifier and words, pictures, symbols which provide general information about the hazards of the chemicals.

Detail information is not required on the label, as long as workers are trained to access additional safety information either on the original label or SDS.

On another note, it may be very difficult to clean the inside of this type of container since it is not removable PRIOR to refilling with a soap product! Full service TMC clients will receive secondary labels via the Label Request Form which is available on the client portal.

HIPAA: Secure Paper Documents

What is a physical safeguard?

Physical safeguards are physical measures, policies, and procedures to protect a covered entity’s electronic information systems, buildings and equipment from environmental hazards and unauthorized intrusion. The standard covers facility access controls, workstation use, workstation security, and device and media controls. A server kept behind a locked door and/or cage onsite is one example. Written policies and procedures must identify how workstations are positioned, who has access to ePHI and their limitations to access, and where maintenance records are stored. The Security Rule requires covered entities to implement physical safeguard standards for their electronic information systems on their premises and any other location used by the entity.