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**>

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 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: f/ghs.html

Rob Toreki

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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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