DCHAS-L Discussion List Archive
Date: Wed, 16 Jun 2010 17:20:14 -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: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Question about EPA Regulation
In-Reply-To: <CE82A091FC41F7488B2C2E8F0FFF6BC804127B030B**At_Symbol_Here**FS2.baylor.edu>
I can't speak to EPA, but
under OSHA if you send samples to a collaborator that is off-site, then
an MSDS is required. See our entry in the MSDS FAQ entry "Do I
have to write an MSDS for new chemicals that I create in the
laboratory?" at
http://www.ilp
i.com/msds/faq/partc.html#laboratory and the references
therein.
Under the current HazCom Standard 29
CFR 1910.1200, no testing is required, so your MSDS can be full of
legitimate "Not known" entries. Things may get more complicated
under the GHS:, so this type of concern is a good one to voice during
the rule making process:
http://www.ilpi.com/msds/re
f/ghs.html
Rob
Toreki
==========
=========================
===================
Safety
Emporium - Lab & Safety Supplies featuring brand
names
On Jun 16, 2010, at 4:51 PM, Humphrey, Karalyn J.
wrote:
We had a peer review audit back in March, and the
violation information that 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 results in the development of a new compound.
This compound must then be characterized, 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,
something along the lines of: "Experimental Material: This
material is not listed on the Toxic Substances Control Act inventory.
It should be used for 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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