Date: Mon, 2 Oct 2006 22:53:23 -0400
Reply-To: Carl Zipfel <czipfel**At_Symbol_Here**COMCAST.NET>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Carl Zipfel <czipfel**At_Symbol_Here**COMCAST.NET>
Subject: Re: Chemical lists for schools

I think some brief comments are warranted here.  While there is some 
truth in the content of this e-mail, there is much incorrect 
information.  I have had no acquaintance with classroom chemical usage 
since I left the university oh so many years ago.  But, to preclude the 
use of all the chemicals on OSHA's Z-1 table would leave students 
unnecessarily missing out on many learning experiences.

. 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 
> 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:

While I would agree that materias covered under regulations 1910-1001 
and higher meet the criterias described, those covered under 1910-1000 
do not.  While the materials refered in OSHA Air Contaminants List are 
associated with some hazards, these hazards range from simple irritation 
to potential carcinogens.  The data used to establish the hazard, and 
the exposure values most often comes from animal data and not human 
exposure data.  In fact there are only a few carcinogens on the list, 
and all are noted with a "C".  But note that the list contain materials 
such as Acetic Acid, Ethanol (think a good shot of Vodka), Sucrose 
(sugar), Starch, Formic Acid (think ant bite), Isopropyl Alcohol (think 
rubbing alcohol), etc.  I think you get the picture.  All, for sure, 
under certain circumstances are associated with some type of hazard.  
Some of those hazards are serious, and some are not so serious.

It should be understood that the exposure levels noted are for workers, 
and for the most part, based on an 8-hr work day, and a 40-hr work week. 
 I would seriously doubt that these exposure levels would be exceeded 
for most of these listed materials in a lecture laboratory.  However, 
that said, the OSHA Z-1 list is a pass=E9 list and very much so 
out-of-date, and I would recommend that the ACGIH list be used instead, 
as it is more up-to-date.  This list would be of extreem value to any 
laboratory, as it can be used as an "indication" of the level of hazard 
associated with certain materials.  But, one needs to understand that 
hazard, the target organs affected, and the precautions that are 
recommended.  That is what MSDS's are for.  All laboratory chemicals 
should be accompanied by an MSDS, without exception.  And, no material 
should be put to use without one.

> 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. 

This is incorrect.  None of the chemicals on the Z-1 list require 
medical monitoring, dedicated areas or systems with warning signs posted 
to segregate these areas. This only applies to the few specific 
materials listed from 1910-1001 and on, as is noted below.

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 
> 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.

I would absolutely agree that the following list be avoided for any 
reason.  But, I would find little value in the use of these materials in 
a lecture laboratory anyways.  And, one should always select materials 
of the lowest hazard when conducting demonstrations.  As an example, one 
may not have to forgo the use of Hydrochloric Acid in a pH 
neutralization demonstration if one uses dilluted HCl in place of of 
concentrated.  Or uses HCl in place of Sulfuric Acid, or Nitric Acid.

> 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 
> 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).

There is no argument here, this is good advice.  Instructors should be 
aware of the risks of such materials that can peroxidize as Ethers.  
And, some materials should always be under lock and key.

Carl Zipfel, csp
EHS Director

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