You are both right. The "experimenting" that goes on in an art department studio should not be called research. It usually is mixing and playing with materials without any knowledge of the chemistry of those materials often endlessly "repeating" the experiments of the past and "rediscovering" the same artistic effects. A typical example is in painting where there is a big push to go back to high lead carbonate white paints, even using them as the ground (which is sanded) for the whole paintings in the belief that the experiments (and the lead poisonings) of the great masters are the ones they should be repeating.
And many printmaking departments are becoming re-enamoured of lead type setting. Ceramic Departments are exposing themselves to clouds of silica and other toxic mineral dusts mixing their own clay from scratch because, in their ignorance, they think it's cheaper than buying premixed clay. But if the art department had to install the right kind of ventilation and institute a proper respiratory protection program for this process, they wouldn't be able to afford this cheaper method. There are pottery teachers, even one famous one, with x-ray demonstrable silicosis.
But EPA sealed our fate when they included "art studios" in educational institutions as labs under their definition in subpart K, so we are stuck with it. And even if the school decides to put them under hazcom instead, the artists object to being lumped in with facilities.
My reports always recommend that if the art department is under the Lab Standard, that they rewrite a subsection of their Chemical Hygiene Plan for art to include addition provisions for training (making it annual like the old hazcom) and labeling that makes that section look just like a Hazcom plan.
And, not to toot my own horn, that training won't work unless the CHO trainer is FULLY versed on the processes in the art department, the types of "experiments" they do, and can address the actual chemicals they use (even though many of the MSDSs and labels do not identify the chemicals in the products due to a perversion of the separate federal labeling law for art materials--which that trainer also needs to fully explain).
And as soon as you find that well-versed CHO, let me know. I have jobs to refer to them.
In a message dated 5/21/2011 6:15:21 AM Eastern Daylight Time, cavanaughmm**At_Symbol_Here**APPSTATE.EDU writes:
If you look at the definition of a lab, the making of art simply doesn=E2=80=99t meet the definition. The artist is creating a product; that makes them subject to HazCom, not the Lab Standard. Perhaps New York has modified its definitions and that makes your situation different from ours; our state uses the same language as federal OSHA.
Please don=E2=80=99t misunderstand what I said about the CHO not being responsible for chemical safety in areas subject to HazCom. What I said was the regulations do not define the CHO as being responsible for chemical safety in non-lab areas.
However, the employer (the university) can certainly define one=E2=80=99s **job** as being responsible for chemical safety regardless of where it occurs or which set of regulations govern the activity. That is what they have done here (I=E2=80=99m both University CHO and HazCom Manager=E2=80=A6 and Biosafety Officer and Exposure Control Officer and=E2=80=A6 well, I digress) and it sounds like that=E2=80=99s what they=E2=80=99ve done with your position.
Mary M. Cavanaugh CIH
Interim Director, Occupational Safety &Health Office
University Industrial Hygienist
Phone 828.262.6838 (Tues-Wed)
Phone 828.262.4008 ext 3# (Mon, Thu, Fri)
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Kim Auletta
Sent: Friday, May 20, 2011 1:44 PM
Subject: Re: [DCHAS-L] Realm of Duties for a Univercity CHO?
Mary - many, including myself, at our university think the art dept and some of the engineering shops are "labs" - they are all research related. Our chemists may have a hard time thinking the art/structural lab as research, but the artists definitely think it is! I provide chemical oversight to all of them. I also manage the MSDSs for all areas, including physical plant sites.
Lab Safety Specialist
Stony Brook University
EH&S Web site: http://www.stonybrook.edu/ehs/lab/
Remember to wash your hands!
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