Georjean,

Contact Kalpana Rengarajan, 404-727-8863 here at Emory.  Many of us in Regi
on 4 had the same finding during our Peer Audits.  I don't believe our new 
guidelines and decision tree is posted yet.

Patty

Patty Olinger, RBP
Director, Environmental, Health, and Safety Office
Emory University
1762 Clifton Rd.
Atlanta, GA 30322
404-727-5690 office
404-727-9778 fax
www.ehso.emory.edu
________________________________________
From: DCHAS-L Discussion List [DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Georjean 
Adams [gla**At_Symbol_Here**EHSSTRATEGIES.COM]
Sent: Thursday, June 10, 2010 7:42 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Question about regulations

I assume this was under TSCA.
Does Baylor have commercial chemical activity?  Are you working on
chemicals that you hope may eventually be commercialized?  If so,
there is a minimum amount of review and documentation required to
qualify for the R&D exemption for new chemical substances
premanufacture notification.  See EPA's site:
http://www.epa.gov/opptintr/newchems/pubs/randdexemp.htm

Requirements depend on who's doing what where.

Georjean Adams


>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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