Date: Fri, 27 Jul 2007 19:24:23 -0700
Reply-To: Lucy Dillman <lucydillman**At_Symbol_Here**COMCAST.NET>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Lucy Dillman <lucydillman**At_Symbol_Here**COMCAST.NET>
Subject: Re: Fwd: Dept of Homeland Secuirty Rule

I think it would be good to include small start-up companies, non-profit
research institutes and governmental research and testing labs along with
universities in this.

The biggest problem with the DHS rule is the definition of chemical
facilities.  My first thought was that the rule could not possibly pertain
to my situation until I read the definitions.

The video of the congressional hearing said something about 10,000
facilities to be monitored, but I have a suspicion that if all small labs
are taken into account that have less than 100 mL of triethanolamine for
example, that there will be many more facilities reporting than they expect.

Best regards,
Lucy Dillman
----- Original Message ----- 
From: "Suzanne Howard" 
Sent: Thursday, July 26, 2007 9:12 AM
Subject: [DCHAS-L] Fwd: Dept of Homeland Secuirty Rule

> This was in the chronicle of higher ed yesterday.
> Federal Panel Will Discuss Modifying Chemical-Security Regulations to Suit
> Needs of Colleges
> [ mailto:lauren.smith**At_Symbol_Here** ]By LAUREN SMITH
> Colleges worried about the costly burden of complying with proposed
> federal regulations on storing hazardous chemicals got some good news at a
> Congressional hearing on Tuesday.
> The U.S. Department of Homeland Security, which had proposed the rules,
> has responded to those worries by establishing a working group to consider
> reasonable ways to tailor the regulations to campuses, said a witness
> testifying at the hearing.
> The department announced last Wednesday that it would form the group, said
> Ara Tahmassian, associate vice president for research compliance at Boston
> University and the witness representing higher education at the hearing.
> The group will begin meeting within the first two weeks of August to
> review and revise the regulations, he said.
> Members of the panel will include representatives of the Association of
> American Universities, the American Council on Education, the Campus
> Safety, Health and Environmental Management Association, the Council on
> Government Relations, the National Association of College and University
> Business Officers, and the National Association of State Universities and
> Land-Grant Colleges. Mr. Tahmassian will also be a member, as well as
> anyone else the representatives believe could make a significant
> contribution.
> The other members are not yet settled, but they are likely to include
> people from leading research universities, said Ada Meloy, director of
> legal and regulatory affairs at the American Council on Education.
> Department officials apparently were receptive to complaints from academe
> that regulations designed for manufacturing plants and other industrial
> settings would not work well on university campuses. "They are absolutely
> open to anything and everything," Mr. Tahmassian said. "They have heard
> what our concerns are, and they accepted they were not familiar with our
> format."
> No official from the department testified at the hearing about the
> regulations' impact on higher education, and calls to the department for
> comment on Tuesday were not returned.
> The hearing, held by the House of Representatives Committee on Homeland
> Security's Subcommittee on Transportation, Security, and Infrastructure
> Protection, convened to discuss the department's antiterrorism standards
> for chemical facilities and their effect on the public and private
> sectors.
> "We are not asking to be exempt from these regulations," said Mr.
> Tahmassian. "We are asking that there is a different standard adopted."
> The "interim final rule," announced by the department in April, would
> require colleges and others to inventory 342 "chemicals of interest." If a
> college exceeded the "threshold quantity" for any of the chemicals, it
> would be required to undergo a risk analysis and possibly submit to
> stricter security requirements. The rule became effective in June, but a
> list of the chemicals and their threshold amounts is still being revised.
> University officials were "surprised" by the new standards because the
> list included a number of compounds that are common in laboratories, said
> Mr. Tahmassian. "In our estimation, as originally published, the rule
> would have applied to virtually every college and university in the
> country, and probably to many hospitals, doctors' offices, and secondary
> schools as well," he said.
> Boston University and its medical center, for example, have about 600 labs
> in 25 buildings on two campuses two miles apart. "On any given day, some
> portion of the chemicals housed in these laboratories is consumed in
> experiments, and others are purchased or prepared as mixtures," he said.
> "Most of these chemicals are stored in small containers, typically ranging
> in size from tiny vials holding a few milliliters up to five-gallon
> bottles."
> Documenting each amount, and setting up a tracking device for them, would
> take longer than the department's 60-day deadline would allow, he said.
> Other witnesses also criticized the deadline and called for sufficient
> time to carry out the regulations efficiently.
> Suzanne Howard
> Director, EHS
> Wellesley College
> 781-283-3882

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