Karen, Are you sure they've audited you to the correct standard (the lab std)? We had a state OSHA inspector come and try to cite us with all sorts of thi ngs from the OSHA standard that applies to industrial manufacturers...all o f his findings against us were vacated when we pointed out his error. I cannot imagine any way that a research organization could accomplish mean ingful research AND complete full risk assessments on each new compound mad e intentionally - much less all of the unintended byproducts that get ident ified (and we won't even mention all of the unidentified gunk!) Brad Sent from my HTC PURE=99, a Windows=AE phone from AT&T -----Original Message----- From: Humphrey, Karalyn J.
Sent: Thursday, June 10, 2010 5:53 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] Question about regulations 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 resea rch groups involved with synthesis. Do any of you have experience with the documentation required for newly syn thesized chemicals? All of the chemicals are for research and development purposes, and all are in small quantities. According to the regulations, a s I understand them, we have to provide notice of health risks that may be associated with exposure to these newly synthesized chemicals. But how? D o 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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