Date: Mon, 2 Oct 2006 14:47:01 -0500
Reply-To: Beth Shepard <bshepard1**At_Symbol_Here**SIAL.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Beth Shepard <bshepard1**At_Symbol_Here**SIAL.COM>
Subject: Fw: [DCHAS-L] Chemical lists for schools
I've never bothered with subpart Z-1, the information I've needed has been 
in the subsections I've listed.

While the dose makes the poison, the dose on water is significantly higher 
than on highly toxic materials. From my high school memories, the 
stockroom was WAY too accessible to have the inorganic cyanides, the DEA 
precursors & essentials, any explosives (ammonium nitrate, 
nitrocellulose), etc. just sitting out on the shelf with everything else. 
If a stockroom decides to carry those items, they should be locked up in a 
separate locked cage area. 
Think about the example of the OTC psuedoephedrine products, which now are 
required to kept behind the pharmacy counter, have limits on the monthly 
purchase, ID required.. That's just to prevent their misuse in 
synthesizing Crystal Meth. Based upon that example, sodium cyanide ought 
not to be sitting on a shelf where anyone (students, faculty or other 
staff) can access it. After someone gets poisoned is a pretty bad time to 
decide that the stockroom security needs to be improved.


Beth Shepard
Technical Specialist, Regulatory Compliance
Sigma-Aldrich, Milwaukee
Phone: (internal) 6-414-5471
Phone: (external) 414-438-3850 ext 5471
FAX: 414-438-4235 or 6-414-5432

10/02/2006 02:26 PM

"Beth Shepard" 

Re: [DCHAS-L] Chemical lists for schools

There are an awful lot of chemicals listed in Subpart Z: See Table Z-1:

Do you think it necessary to ban 
Acetic acid ? (vinegar)
Ammonia?  There're probably a bottle under the kitchen sink at home

Clearly, confirmed carcinogens are not a good idea, but a blanket ban on 
anything listed in Subpart Z is neither necessary or desirable.

In the right/wrong hands, ANY chemical can be deadly.  Even distilled 
water has an LD50.  The dose makes the poison.

-----Original message-----
From: Beth Shepard bshepard1**At_Symbol_Here**SIAL.COM
Date: Mon, 02 Oct 2006 13:43:38 -0500
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Chemical lists for schools

> Hello--
> While it may be very difficult to compile a list of chemicals that 
> be in a high school storeroom, it is much easier to create a list of 
> chemicals to exclude of minimize. In my opinion, all of the chemicals on 

> OSHA's Subpart Z list should be minimized or excluded. The Subpart Z 
> consists of the chemicals that OSHA considers to be confirmed as a cause 

> of human health problems (mostly cancer). These conclusions have been 
> created based upon the human epidemiological studies rather than just 
> animal studies. Most of them have specific requirements for workers 
> involved in the production, handling & use of these materials. The 
> specific regulations can be accessed through the website shown below 
> (29CFR Part 1910.1000-1096:

> All of the chemicals listed in Subpart Z require air monitoring to 
> quantify the exposure levels, most of them require medical monitoring, & 

> some of the chemicals require dedicated areas & systems with warning 
> posted to segregate these areas. While OSHA's regulations do not cover 
> students, I would think they would cover the instructors. But, 
> of the applicability of these regulations to a school setting, I believe 

> there is no reason to expose the student, instructors, & other school 
> employees to the potential health risk these materials can cause, 
> especially if there is a less hazardous alternative available.
> 1910.1003       13 carcinogens including  4-nitrobiphenyl
> 1910.1004       alpha-Naphthylamine.
> 1910.1006       Methyl chloromethyl ether
> 1910.1007       3,3'-Dichlorobenzidine (& its salts)
> 1910.1008       bis-Chloromethyl ether
> 1910.1009       beta-Naphthylamine
> 1910.1010       Benzidine
> 1910.1011       4-Aminodiphenyl
> 1910.1012       Ethyleneimine
> 1910.1013       beta-Propiolactone
> 1910.1014       2-Acetylaminofluorene
> 1910.1015       4-Dimethylaminoazobenzene
> 1910.1016       N-Nitrosodimethylamine
> 1910.1017       Vinyl chloride
> 1910.1018       Inorganic arsenic (compounds)
> 1910.1025       Lead 
> 1910.1026       Chromium(VI) (compounds)
> 1910.1027       Cadmium (& compounds)
> 1910.1028       Benzene
> 1910.1044       1,2-Dibromo-2-chloropropane
> 1910.1045       Acrylonitrile
> 1910.1047       Ethylene oxide
> 1910.1048       Formaldehyde
> 1910.1050       Methylenedianiline
> 1910.1051       1,3-Butadiene
> 1910.1052       Methylene chloride
> In my opinion, other chemicals to be wary of include those that form 
> peroxides relatively quickly, are explosive or can be easily converted 
> explosives, are highly toxic, are named within the DEA regulation or are 

> on the DEA Chemicals of Concern list. Some of these categories are due 
> lab safety issues, others are due to security/liability issues (how to 
> keep the chemicals from being misappropriated for illegal uses).
> Beth Shepard
> Technical Specialist, Regulatory Compliance
> Sigma-Aldrich, Milwaukee
> Phone: (internal) 6-414-5471
> Phone: (external) 414-438-3850 ext 5471
> FAX: 414-438-4235 or 6-414-5432

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