Roger O. McClellan
Advisor, Toxicology and Human Health Risk Analysis
----- Original Message -----
...on the OSHA side however, any notion that one can simp ly claim that "it=E2=80=99s R&D=" or that "it=E2 =80=99s small quantity=" and then cite one=E2=80=99s control banding system or the lab standard won=E2=80=99t get you out of issues regarding M SDS development, etc. if sending samples, etc. off-site
http://www.osha.gov /pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=203 90
On a developing note, I suggest keeping an eye on debate and likely promulgation of the updated HazCom Std. as it relates to hazard classification.
http:// www.regulations.gov/search/Regs/home.html#docketDetail?R=OSHA-H022K-2006- 0062
Steve Crooks, MS, CIH, CSP
People, Property & Environmental Protection, Inc.
12 Reynard Place
Hillsboroug h, NC 27278
/B> DCHAS-L Disc
ussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Michael Coope
Sent: Thursday, June 10, 2010 8:06 PM
To: DCHAS-L**At_Symbol_Here**LIS T.UVM.EDU
Subject: Re: [DCHAS-L] Question about regulations
If the violation was based on EPA TSC A rules then the University should be able to claim < SPAN style="FONT-FAMILY: Consolas">a R&D exemption - this assumes that the quantity limits are met and the R&D materials would not find thei r way into commercial use with out further evaluation. On the OSHA side, handling/use issues likewise arise in industrial laboratories doing synthesis work with "new or unknown" ch emicals. There are several schemes patterned after the chemical banding approach (fi rst promulgated in the Pharma industry) to categorize chemic als for handling/use when little information about toxicity has been gather ed. These can be shared - let me know if needed.
Mi chael N. Cooper MS, MPH, CIH
Senior Managing Scientist
Exponent / Failure Analysis Associates
149 Commonwealth Drive
Menlo Park, California 94025< P>mcooper**At_Symbol_Here**exponent.c om
c ell (408) 313-2127
office (650) 688-1760
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Humphrey, Karalyn J.
Sent: Thursday, June 10, 2010 2:14 PM
To: DC HAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Question about regulations< /P>
My name is Karen Humphrey and I'm the safe ty 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 docume ntation for new chemicals made by our research groups involved with synthes is.
Do any of you have experience with the documentation required for newly synthesized c hemicals? All of the chemicals are for research and development purpo ses, 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 ho w? Do we need to generate some kind of MSDS, or is there a labeling s ystem that is used?
T hank you in advance for your help.
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