Date: Sun, 13 Jun 2010 10:53:56 -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: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: Question about regulations
In-Reply-To: <509159.54905.qm**At_Symbol_Here**>
Yes, the most important question is whether you have everything in place to cover all faculty, staff and students, etc., with questions of regulatory compliance secondary.  But in a discussion list, it is worth remembering that sometimes a question is posed by someone who really needs responses to the latter (regulatory compliance).  Answering the former can then be unresponsive to the question. 
Ambiguity arises when, as is often the case, the questioner is not so painfully explicit as to say, "I'm really, really only interested in regulatory compliance just now."

Peter Zavon, CIH
Penfield, NY


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Roger McClellan
Sent: Saturday, June 12, 2010 6:55 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Question about regulations

To all:
   This exchange ,as are many others on DCHAS-L, is very interesting!! I make the following comment in the abstract without regard to this specific question.
     Sometimes I think the questions are framed very tightly in terms of what does the Institution need to do to achieve regulatory compliance, ie show that we followed the rules and dotted the i's and crossed the t's.
     I suggest that the more appropriate approach is -- do we have in place the proper policies and procedures, training programs, the required facities and equipment and Institutional culture to ensure that ALL faculty, staff and students are carrying out all activities in a safe manner with the lowest potential for the occurence of untoward  events that may impact on their health and well-being? After answering that question it is appropriate to ask, are we meeting all applicable regulations, meeting the regulations is secondary to what I outlined.
     Best wishes to all for providing a safe work environment for all. and, by the way, meeting the regs.

Roger O. McClellan


Advisor, Toxicology and Human Health Risk Analysis

13701 Quaking Aspen Place NE
Albuquerque, NM 87111
Tel: 505-296-7083
Fax: 505-296-9573
E-mail: roger.o.mcclellan**At_Symbol_Here**

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