Date: Mon, 2 Oct 2006 20:56:12 -0400
Reply-To: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: Chemical lists for schools
In-Reply-To: <OF6A9355BE.12E5097E-ON862571FB.006186C6-862571FB.0064601A**At_Symbol_Here**>
I am certain that Beth Shepard means well, but her description of the
materials in OSHA's Subpart Z is valid only for the very few materials with
specific standards that she listed in her note.  The vast majority of
materials listed in Subpart Z are in Table Z-1 of 1910.1000 (also called the
Air Contaminants Table).  The several hundred materials in that list are
mostly NOT suspected as carcinogens, are listed on the basis of animal
studies as much as on human, do NOT have specific requirements for the
workers using them, do NOT require medical monitoring of workers, and none
of them require dedicated areas and warning signs under the existing OSHA

The 30 or so materials covered in the specific standards may well be
appropriate for exclusion from school chemistry work.

However, in my opinion it is not reasonable to use the Z Tables as an
exclusion list for school chemistry activities. 

Peter Zavon, CIH
Penfield, NY


> -----Original Message-----
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] 
> On Behalf Of Beth Shepard
> Sent: Monday, October 02, 2006 2:19 PM
> 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 should 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 list 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:
> p?p_toc_level=1&p_part_number=1910 
> 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 signs posted to 
> segregate these areas. While OSHA's regulations do not cover 
> students, I would think they would cover the instructors. 
> But, regardless 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 to 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 to 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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