Date: Thu, 21 Jan 2010 21:39:03 -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: Andrew Gross <gross.drew**At_Symbol_Here**GMAIL.COM>
Subject: Re: OSHA Regulations, New York
Comments: To: g.c.walton**At_Symbol_Here**
In-Reply-To: <5662DAFC6CD44BCA8E177EC717F5597C**At_Symbol_Here**Georgedesktop>

As always thank you.  The mere mention of OSHA with rule citations in
hand created enough waves that my point was made...someone high up in
the company made the analysis.  I don't know what they were thinking
to check a flash point for just a few $$$$, but so long as it was not
me, or someone who my responsibility falls upon is fine.  The person
who ran flash has the experience and education to know the risks so,
what ever.

We are a laboratory, plenty of fume hoods and ppe, however we are set
up for industrial effluent, not raw chemicals of unknown nature.  What
annoyed me most was the assignment was identification...flash point
was going to get us no where with that.  Our flash apparatus can't be
moved under a proper hood for this chemical.

I made numerous suggestions.  Most included outsourcing analysis and
disposal or at least sending a small sample to a nearby university
with NMR so at least we had a better idea of what it was and how to
protect ourselves.  None the less, we are a small and cash strapped
company and they wanted the profits for themselves.  In my opinion a
stupid and potentially move.

I reiterate...what ever.

Thanks to everyone one more time.

On Thu, Jan 21, 2010 at 6:12 PM, George Walton  w
> This is submitted to provide a possible way to resolve the issue of worki
> with unknown or poorly characterized material. =A0Only paragraph headings
> a few brief notes are included.
> 29 CFR 1910 Subpart I -- Personal Protective Equipment
> 1910.132 General Requirements
> =A0 =A0 =A0 =A0(a) Application: =A0the verb used is shall, as in mandator
> =A0 =A0 =A0 =A0(d) Hazard assessment and equipment: again, the verb used 
is shall.
> This paragraph includes a note: =A0Non-mandatory Appendix B contains an
> example of procedures that would comply with the requirements of a hazard
> assessment. =A0(I read that as meaning an assessment must be done. =A0Thi
s is a
> performance, not a specification, standard so the format of the required
> assessment can vary.)
> Appendix B to Subpart I of 1910: Non-mandatory Compliance Guidelines (my
> note: again, the requirement is for the hazard assessment, the format of 
> hazard assessment may vary)
> 1. Controlling hazards
> 2. Assessment and selection
> 3. Assessment guidelines
> =A0 =A0 =A0 =A0a. Survey
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0(d) chemical
> =A0 =A0 =A0 =A0b. Sources
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0(c) type of chemical exposure
> =A0 =A0 =A0 =A0d. Analyze data: determine type of hazard; level of risk;
> seriousness of potential injury
> 4. Selection guidelines
> 11. Selection guidelines for hand protection
> My notes: I picked the citations that may be more appropriate. =A0Appendi
x B
> is at the end of Subpart I (after 1910.139), not after Section 1910.132.
> George Walton
> 757-436-1033

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