Date: Thu, 21 Jan 2010 16:38:11 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Samuella B. Sigmann" <sigmannsb**At_Symbol_Here**APPSTATE.EDU>
Subject: Re: OSHA Regulations, New York
In-Reply-To: <2317fc9b1001211003l7642859pab90436eb9694c70**At_Symbol_Here**>

I cannot remember what type of operation you have, but if there is any 
production, you will not be under the lab standard as far as 
regulations.  If you do not have hoods, then you may not meet the Lab 
Standard.  As I recall, you said that this chemical is in 55 gallon 
drums.  This probably means that you do not meet the definition of 
"Laboratory Scale" either. 

Your operation would still fall under the General Duty Clause.
> SEC. 5. Duties
> (a) Each employer --
> (1) shall furnish to each of his employees employment and a place of 
> employment which are free from recognized hazards that are causing or 
> are likely to cause death or serious physical harm to his employees;
> (2) shall comply with occupational safety and health standards 
> promulgated under this Act.
> (b) Each employee shall comply with occupational safety and health 
> standards and all rules, regulations, and orders issued pursuant to 
> this Act which are applicable to his own actions and conduct.

Andrew Gross wrote:
> Hi Everyone,
> Back to that unknown chemical that has been hauting me.  Well, I'm
> still being pressured to continue the flash test with no protection.
> I said no, someone used the word insubordination and today I offered
> to cite osha regulations.  I would like to follow through with my
> threat.
> Anyone know the OSHA regulation that covers working with unknown
> hazardous materials (corrosives with toxic effects on inhalation)
> without proper ppe?  As I explained, to them, its a light molecule and
> anything short of SCBA will be insufficient respirtory protection.
> I would like to make it very clear that I am not going to get
> injured/die for an analytical test that could be done much safer in a
> properly equipped facility.   Nor do I want to hear about it anymore
> and I won't allow one of my technicians to test it just because they
> don't have the chemical background to understand the dangers..
> Next step will be a call to OSHA if they don't get the hint.
> Thanks in advance.
> Andrew

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