Date: Fri, 26 May 2006 15:50:47 -0400
Reply-To: "George Thompson, PhD." <georgethompson**At_Symbol_Here**CHEMPLY.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "George Thompson, PhD." <georgethompson**At_Symbol_Here**CHEMPLY.COM>
Subject: Re: MSDS question
Comments: To: Robert Belford


Your question is a good one, and your presumption of a broadbased 
malpractice within industry and academic labs may very well be correct. 
If so, one can reasonably expect an increasing number of lawsuits in 
this area for a number of reasons.

First, the "prudent man" concept in tort law requires that employers 
implement worker safety and health procedures that avoid reasonably 
anticipated hazardous exposures. The logic you posed behind your 
question clearly indicates that your laboratory has violated this most 
basic standard.

Second, the OSHA laboratory standard (29 CFR 1910.1450) defines that 
your laboratory Chemical Hygiene Plan (CHP:

  "...sets forth procedures, equipment personal protective equipment and 
work practices that (i) are capable of protecting employees from the 
health hazards presented by hazardous chemics used in that particular 
workplace....[see paragraph (6) and (e)]
In fact, the purpose of the CHP is "protecting employees from health 
hazards associated with hazardous chemicals in that laboratory" [Note: 
not in the stockroom!].

Third, although the Lab Standard does refer to making "reference 
material...including, but not limited to Material Safety Data Sheets 
received from the chemical supplier" (see paragraph (f)(3)(v)], 
elsewhere the Standard states that hazardous "chemical substances 
developed in the laboratory...[require] appropriate training" [see 
paragraph (h)(2)(i)], and

    "If the chemical substance is produced for another user outside of 
the laboratory [in your case, think "outside of the stockroom"], the 
employer shall comply with the Hazard Communication Standard (29 CFR 
1910.1200) including the requirements for preparation of material safety 
data sheets and labeling"
    [see paragraph (h)(2)(iii)].

The bottom line: the CHP is incomplete if it does not include health 
hazards for solubilized solids, training will be inaequate, and required 
"reference material" [see paragraph (f)(3)(v)] will be missing. I 
believe these could be three OSHA citations.


George R. Thompson, Ph.D.
President & CEO
Chemical Compliance Systems, Inc.
706 Route 15 South, Suite 207
Lake Hopatcong, NJ 07849
973-663-2148 (ext. 234)
973-663-2378 (fax)

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----- Original Message ----- 
From: "Robert Belford" 
Sent: Thursday, May 25, 2006 12:24 PM
Subject: [DCHAS-L] MSDS question

> We keep manufacturer's MSDS for the compounds we use in the labs.  
Let's say we have solid potassium permanganate from JT Baker.
> and we create a 0.1N solution for a lab like
> and a student drinks a gallon of the stuff...!#$**At_Symbol_Here**!....
> Should we induce vomiting?
> The actual MSDS for the solid that we bought says no, while if we had 
bought the solution we made, it would say yes.  
> Now, my question is not really should we induce/not induce vomiting 
for this hypothetical and hopefully absurd scenario, but is it 
sufficient to provide manufacture's MSDS in a stock room based on the 
material purchased.  This scenario indicates to me that such a system is 
inadvisable, yet I suspect, that for obvious reasons, it is common.  I 
mean, you buy a chemical, and you file the manufacturer's MSDS for the 
chemical you bought.  That seems logical and prudent, although I doubt 
it is, yet, I am sure such practice is common in industry and many 
academic labs.  Does anyone have a written policy for filing MSDS that 
covers this?
> Also, are there other cases where dilution changes first aid 
> Thanks,
> Bob Belford
> *****************************************
> Dr. Robert E. Belford
> Department of Chemistry
> University of Arkansas at Little Rock
> 2801 S. University 
> Little Rock, AR 72204-1099
> rebelford**At_Symbol_Here**
> 501-569-8824
> ********************************
> ********************************

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