Dear CHAS, The Building Code rules here with the Fire Marshal and building inspectors. Those folks do not enforce any OSHA or EPA regs. Janet Baum, AIA, Principal Health, Education + Research Associates, Inc. -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Gordon Miller Sent: Monday, May 21, 2007 10:03 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] NFPA standards Unfortunately, safety can be summarized by paraphrasing Mao ze Dong. He said "Justice grows from the barrel of a gun." Figuratively, safety grows from the barrel of a gun. The gun is enforcement. Fire Marshals can enforce NFPA45, etc. and they have significant enforcement authority. NFPA IS regulatory with more certain enforcement, via fire inspections, than OSHA or EPA. > > >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 > >________________________________ > > > >