Regulatory Activity

Deadlines to comply with Washington’s new hazard communication rules differ from OSHA

The Occupational Safety and Health Administration (OSHA) recently revised the Hazard Communication Standard in order to improve comprehension of hazard information found on product labels. Safety Data Sheets (SDSs) will replace the current Material Safety Data Sheets (MSDSs), which will more effectively prevent injuries and make it safer for workers to do their jobs.

The federal deadline for compliance to train employees is December 1, 2013. In Washington, however, the WA Industrial Safety and Health Act (WISHA), doesn’t require compliance to begin until June 1, 2014. WISHA supersedes OSHA for all but federal workers.

But that doesn’t mean you should wait to prepare.

Major changes to the hazard communication standard include the following four areas:

  1. Hazard Classification: For each chemical, the chemical manufacturer or importer must determine the hazard classes, and where appropriate, the category of each class that applies to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the manufacturer’s classification.
  2. Labels: The information on labels will become more standardized to increase employee comprehension of the potential hazards and precautions. New labels will feature hazard pictograms, a signal word such as “danger,” hazard and precautionary statements and both a product and supplier identifier.
  3. Safety Data Sheets: The new standard will have a specified 16-section format and replace what is currently known as a Material Safety Data Sheet (MSDS).
  4. Information and training: Employers are required to train workers by June 1, 2014 on the new label elements and SDS format to facilitate recognition and understanding.

Written Hazard Communication Plan
Employers must develop, implement, and maintain a written hazard communication program which describes how the criteria for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which includes the following:

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Prescription Monitoring Program data collection resumes July 1

Veterinarians that dispense Schedules II, III, IV, and V controlled substances in Washington State, or send such substances to an address in the state, must resume reporting to the WA PMP. Data collection resumes July 1, 2013 and covers data through September 30, 2013, with the first report due October 10, 2013. Reports can be submitted with previously established accounts through Health Information Designs (HID), Inc.

What’s New in 2013

  • Quarterly reporting (used to be weekly)
  • Reporting a greater-than-14-day supply of Schedule II, III, IV and V controlled substances (use to be more than one day supply)
  • Report fewer data fields
  • Submit report electronically or by paper (used to be only electronic)

RCW 70.225, authorized the Washington State Department of Health to establish the Washington State Prescription Monitoring Program. Pharmacies and practitioners that dispense any Schedule II, III, IV, and V controlled substances must report dispensing to the PMP. Mandatory reporting began on October 7, 2011.

WSVMA’s Substitute Senate Bill 6105 (2012 Legislation) was signed into law on March 29, 2012. The law required the Department of Health to work with the Veterinary Board of Governors to establish alternative data reporting requirements for veterinarians by either electronic or non-electronic methods. Final rules to implement these changes became effective June 28, 2013. The first reporting period for veterinarians under the new rule will be July 1, 2013 to Sept. 30, 2013. The report for this period will be due no later than Oct. 10, 2013 based on the new quarterly schedule outlined in the rule. Veterinarians are required to report the dispensing of controlled substances (Schedule II-V) and drugs identified by the board of pharmacy under WAC 246-470-020, dispensed for more than a fourteen day supply.

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Important law change for controlled substances

In addition to the resumption of the Prescription Monitoring Program, another change to controlled substance laws takes place at the end of the month. Effective July 28, 2013, all Schedule III through V controlled substances must be dispensed pursuant to a written, oral, or electronically transmitted prescription. The law states that “any oral prescription must be promptly reduced to writing.”

Senate Bill 5416 amended RCW 69.50.308 Prescriptions, and supersedesWAC 246-887-030, which allows for the dispensing of certain Schedule V drugs without a prescription. The new requirements provide an exception to practitioners who administer the drug directly to the patient.

The amended law also requires that a prescription for a Schedule III through V drug may not be filled or refilled more than six months after the date issued by the practitioner, or be refilled more than five times unless renewed by the practitioner.

For more information, contact the WA Board of Pharmacy at (360) 236-4834.

As a reminder, data collection for the Prescription Monitoring Program resumes this month with the first report due October 10, 2013. For complete information on changes to the Prescription Monitoring Program, visit the WSVMA website.

 

USDA Issues Final Rule for Animal Disease Traceability

WASHINGTON, December 20, 2012—The U.S. Department of Agriculture (USDA) today announced a final rule establishing general regulations for improving the traceability of U.S. livestock moving interstate.

“With the final rule announced today, the United States now has a flexible, effective animal disease traceability system for livestock moving interstate, without undue burdens for ranchers and U.S. livestock businesses,” said Agriculture Secretary Tom Vilsack. “The final rule meets the diverse needs of the countryside where states and tribes can develop systems for tracking animals that work best for them and their producers, while addressing any gaps in our overall disease response efforts. Over the past several years, USDA has listened carefully to America's farmers and ranchers, working collaboratively to establish a system of tools and safeguards that will help us target when and where animal diseases occur, and help us respond quickly.”

Under the final rule, unless specifically exempted, livestock moved interstate would have to be officially identified and accompanied by an interstate certificate of veterinary inspection or other documentation, such as owner-shipper statements or brand certificates.

After considering the public comments received, the final rule has several differences from the proposed rule issued in August 2011. These include:

  • Accepting the use of brands, tattoos and brand registration as official identification when accepted by the shipping and receiving States or Tribes
  • Permanently maintaining the use of backtags as an alternative to official eartags for cattle and bison moved directly to slaughter
  • Accepting movement documentation other than an Interstate Certificate of Veterinary Inspection (ICVI) for all ages and classes of cattle when accepted by the shipping and receiving States or Tribes
  • Clarifying that all livestock moved interstate to a custom slaughter facility are exempt from the regulations
  • Exempting chicks moved interstate from a hatchery from the official identification requirements

Beef cattle under 18 months of age, unless they are moved interstate for shows, exhibitions, rodeos, or recreational events, are exempt from the official identification requirement in this rule. These specific traceability requirements for this group will be addressed in separate rulemaking, allowing APHIS to work closely with industry to ensure the effective implementation of the identification requirements.

For more specific details about the regulation and how it will affect producers, visit www.aphis.usda.gov/traceability.

Animal disease traceability, or knowing where diseased and at-risk animals are, where they've been, and when, is very important to ensure a rapid response when animal disease events take place. An efficient and accurate animal disease traceability system helps reduce the number of animals involved in an investigation, reduces the time needed to respond, and decreases the cost to producers and the government.

This notice is expected to be published in the December 28 Federal Register.

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