Date: Thu, 10 Jun 2010 19:51:24 -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: "Norwood, Brad" <Brad.Norwood**At_Symbol_Here**ARISTALABS.COM>
Subject: Re: Question about regulations


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!)


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


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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