I sounds as though some of them are as easily confused as we are.
Is there some subtlety of wording that I’m missing here?
Sheila Kennedy, C.H.O.
Safety Coordinator | Teaching Laboratories
UCSD Chemistry & Biochemistry |MC 0303
Office: (858) 534-0221 | Fax: (858) 534-7687
From: Kim Gates [mailto:kim.gates**At_Symbol_Here**stonybrook.edu]
Sent: Wednesday, November 20, 2013 10:45 AM
To: Kennedy, Sheila
Subject: GHS/Label issue
Sheila - I read your email on DCHAS abt GHS & labels:
PLEASE correct me if I have this wrong, but my understanding is that the new GHS requirements (HazComm2012) is part of the Hazard Communications Standard. Laboratories such as ours work under the Laboratory Standard, which doesn't include these new standards. Neither one strictly applies to students, who are not employees.
I am in 100% agreement with you about label requirements & haz com vs. labs. The Lab Std only says not to deface incoming labels & label when chems leave the lab as per haz com. I have a copy of the preamble (yes, I'm that geeky) and it states:
"To avoid any confusion which could arise regarding hazard identification relating to the HCS as distinct from that relating to this standard, OSHA has added three clarifying statements regarding laboratory generated chemical substances"....
The Lab standard has no requirement for labeling secondary containers and makes the point that these chemicals are different from HCS labels.
So - my big question - how does OSHA post this handout on their web site for lab standard?
this says laboratory containers must be labeled as per HCS!
Have you guys thought abt this problem? What did you decide?
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