The 1982 version of NFPA 45 is referenced in the OSHA standard, and, as is common, it has been updated about 5 times since then. We usually encourage (or, at least, do not discourage) employers to comply with the most recent version of consensus standards, although we cannot enforce the updated versions. It is normally far easier for a local fire code to be updated than a federal OSHA standard, as you all know. If there is a difference between what we enforce vs the fire marshal, we usually acquiesce to the fire marshal. For the record, the MN State Fire Marshal enforces an amended version of the International Fire Code. - Diane Amell, MNOSHA Staff opinion: Unless otherwise noted, the response provided above is a staff opinion provided by a member of the Minnesota Occupational Safety and Health Compliance Division. A staff opinion is the opinion of one staff member about the correct answer to a specific question generated by a stakeholder. The opinion is not binding. This e-mail and any attachments are confidential and may be privileged. If you are not the intended recipient, or the person responsible for delivering it to the intended recipient, please notify the sender immediately by replying to this message and destroy all copies of this message and the attachments. >>> "Wawzyniecki Jr, Stefan"
5/21/2007 8:02 AM >>> 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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