Date: Thu, 10 Jun 2010 23:41:14 -0400
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: B Rayfield <barryrayfield**At_Symbol_Here**NC.RR.COM>
Subject: Re: Question about regulations
In-Reply-To: <CE82A091FC41F7488B2C2E8F0FFF6BC804116EF189**At_Symbol_Here**>

EPA was probably citing the SNR (significant new use) section in TSCA.  
You are on the right track with the need for hazcom, MSDS and other 
hazard assessments, but unless this is being made for use immediately in 
a non-R&D application, EPA may not be playing by their own rules (a 
common issue lately).  Small volume R&D synthesis is generally exempt 
from TSCA, but synthesis for direct use in a product without evaluation 
of the associated health risks of the substance could trigger a SNR 
designation.  The EU REACh directive has similar risk assessment 
requirements, and EPA really wants to go down a similar path.

Hope this helps,
Barry Rayfield

On 6/10/2010 5:14 PM, Humphrey, Karalyn J. wrote:
> Hello,
> My name is Karen Humphrey and I'm the safety officer for Baylor's Chemistry Department.  I'm trying to sort out the violations we received from an EPA audit that was done recently.  One of the violations that we received was for not having the proper documentation for new chemicals made by our research groups involved with synthesis.
> Do any of you have experience with the documentation required for newly synthesized chemicals?  All of the chemicals are for research and development purposes, and all are in small quantities.  According to the regulations, as I understand them, we have to provide notice of health risks that may be associated with exposure to these newly synthesized chemicals.  But how?  Do we need to generate some kind of MSDS, or is there a labeling system that is used?
> Thank you in advance for your help.
> Karen Humphrey

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