Date: Mon, 21 May 2007 09:02:57 -0400
Reply-To: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Subject: Re: NFPA standards
In-Reply-To: <DAE1D18DA139B54CB83853D6B5F838650A13C149**At_Symbol_Here**>

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




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