Date: Wed, 16 Jun 2010 15:51:12 -0500
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: "Humphrey, Karalyn J." <Karalyn_Humphrey**At_Symbol_Here**BAYLOR.EDU>
Subject: Re: Question about EPA Regulation
In-Reply-To: <DCHAS-L%201006110001188295.000E**At_Symbol_Here**LIST.UVM.EDU>

We had a peer review audit back in March, and the violation information tha
t was given to us was a bit sketchy, at least to my mind.  

We are a university, and as such we carry out research that sometimes resul
ts in the development of a new compound. This compound must then be charact
erized, sometimes in house and sometimes at other facilities.  The amounts 
sent off are small quantities, and the current question seems to be whether
 or not we come under 40 CFR 720.36 (b)(1) or 40 CFR 720.36 (b)(2).

In other words, do we need to characterize the risks of these new compounds
, or will we be in compliance by having a warning accompany the compound, s
omething along the lines of: "Experimental Material:  This material is not 
listed on the Toxic Substances Control Act inventory.  It should be used fo
r research  and development purposes only under the direct supervision of a
 technically qualified individual."

Laboratory Coordinator & Safety Officer / Part-time Lecturer
Baylor Univ. Dept. of Chemistry and Biochemistry
Office: BSB E.111
Phone: (254) 710-2002

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