Bob, Arkansas is a non-plan state. This means state schools are not directly covered by OSHA all the way up to higher education. If you are private, however, you ARE covered by OSHA (at least in higher education, I'm not certain about K-12). I was the CHP for the Chemistry Department at UCA (state) for many years (perhaps you know Mike Rapp?) and have been at Hendrix (private) for several years now. There is a state regulation from the Department of Labor called "The Public Employees Chemical Right-to-Know Act" that does apply to state agencies. I would assume this includes K-12 but I'm not positive. Hazardous waste regulations in the state would come from the ADEQ (Arkansas Department of Environmental Quality) formerly the PC&E (Department of Pollution Control and Ecology) and I think EPA applies to everyone. Keep in mind that legally these regulations only apply to employees (anyone who is being compensated for their work) not students. Obviously the safety of the students should be high on the list of priorities. Please correct me from the list if I'm wrong guys. Let me know if I can help. Shelly Bradley Laboratory Coordinator Chemistry Department Chemical Compliance Hendrix College 1600 Washington Ave. Conway, AR 72032 (501) 450-3812 bradley**At_Symbol_Here**hendrix.edu -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Robert E. Belford Sent: Thursday, December 07, 2006 12:21 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] Fw: CHP's Folks, I forwarded Ralph Stewart's recent post on the "School Chemistry Laboratory Safety Guide" to the Arkansas Sceince Teachers Listserv (K-12) and it started a buzz. I'd like to know if anyone on this list could input on this response (below) and I will forward it to the science listserv. I am not a CHO, have had minimal training and so am hesitant to respond authoritatively. I think there are two questions at hand; are high schools in Arkansas required to have a CHP, and has having a CHP helped a school in an actual court case? Thanks Bob Belford Dr. Robert E. Belford Department of Chemistry University of Arkansas at Little Rock www.ualr.edu/rebelford (501)569-8824 ----- Original Message ----- From: "Dennis Brown"
To: Sent: Thursday, December 07, 2006 11:51 AM Subject: CHP's Ok, help me here. Bill, your statement on the last email concerning CHPs and the OSHA requirements has me a little confused(copy is below). Below is the standard you referenced. I noticed on the title that is says both RECOMMENDATIONS AND Non-mandatory(copy is below). I also understood from past discussions that OSHA requirements do not apply to schools. Am I wrong here? While I understand the benefit and we are presently working on a CHP because we understand the benefit of having one, is there anything PUBLISHED, either state or federal, which REQUIRES a CHP of schools? If we have to have a CHP then why not a CHO? I thought that was discussed on OSHA site as well. Does anyone know about court cases from past school accidents where having a CHP was beneficial to the individual or the school? (I know that misfeasance and negligence enter in here but I am not talking about that.) Bill's statement in the last email. 2. It applies to school employees who work in laboratory settings (i.e., science teachers and lab assistants); indirectly it may serve to protect students. OSHA SITE - TITLE PG * Part Number: 1910 * Part Title: Occupational Safety and Health Standards * Subpart: Z * Subpart Title: Toxic and Hazardous Substances * Standard Number: 1910.1450 App A * Title: National Research Council Recommendations Concerning Chemical Hygiene in Laboratories (Non-Mandatory) Thanks, D. Brown
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