Date: Thu, 17 Feb 2011 19:35:02 -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: Ralph Stuart <rstuart**At_Symbol_Here**UVM.EDU>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
In-Reply-To: <588132.55116.qm**At_Symbol_Here**>
> >I advise my clients during inspections to replace any chemicals older 
than a year. That helps eliminate the inherently waste-like, speculative 
accumulation, etc practices EPA folks like to cite.

I agree that that is good advice, but we advise someone who has 
"perfectly good" chemicals that are more than a year old that they want 
to keep to label them with an inspection date so that the EPA concern 
about their inherently waste-like nature is rebutted. We recommend that 
such inspections happen annually to demonstrate prudent approach in 
chemical inventory management.

This has worked for us in some cases during a couple of different 
inspections, although there were some arguments that we lost on the 
issue as well.

- Ralph 

Ralph Stuart, CIH 
Environmental Safety Manager 
University of Vermont 
Environmental Safety Facility 
667 Spear St. Burlington, VT  05405 


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