Date: Mon, 21 May 2007 09:51:59 -0500
Reply-To: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Subject: Re: NFPA standards
Comments: To: Stefan Wawzyniecki Jr
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
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and Health Compliance Division. A staff opinion is the opinion of one
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>>> "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
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
segregating), it appears that the NFPA holds them to higher standards.
Researchers are questioning this.   And even if they comply by
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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