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Recently our Fire Marshall began a series of Lab Inspections, concentrating primarily on quantities of chemicals. This required all the researchers to provide an inventory for the labs, which was not a problem, since one is required as part of the University's Chemical Hygiene Plan. My question to the List is : OSHA's Lab standard is performance-based, and Law; EPA's RCRA regulations, while prescriptive, have become institutionalized because no one wants a Consent Order (speaking from experience). NFPA 45 is not Law, yet seems to trump OSHA & RCRA, because Building Codes make it appear regulatory. Even if a researcher manages his/her chemical inventory properly (labeling, segregating), and their hazardous wastes properly (labeling, segregating), it appears that the NFPA holds them to higher standards. Researchers are questioning this. And even if they comply by removing some chemicals , they say they will just order more after the Fire Marshall inspection is completed. Are any EH &S professionals finding this a problem? ________________________________ ________________________________ Stefan Wawzyniecki, CIH, CHMM NRCC-CHO University of Connecticut Chemical Health & Safety ________________________________