Before seeing if the exceptions apply, would it be wise to evaluate the toxicity of whatever is included in "a kit?" Maybe, our key(s) need to be identifying/ensuring:
A. "no potential for employee exposure"
B. What would/could the consequences be of an unintended employee exposure to a highly hazardous or toxic compound, since an accident can happen.
C. What is your potential liability, if you do not look at the potential consequences?
I may be getting paranoid, which could either be based upon the experiences of lessons learned over many years or simply my age.
But, I have seen multitudes of "kits" with non-hazardous compounds that would not result in a significant event if a step in the test procedure went conceivable wrong, but I have found enough potentials to make me want to take a keen notice to eliminate or at least control the hazard. (From the top of my head, think sodium azide, Karen Wennerstrom with dimethyl mercury, pyrophorics, etc.) Now where is that list of lessons learned from laboratory experiments gone wrong? We used to have a list that I referred to often, long before the CSB started to notice.
While I am not sure about the contents of the kits, some may be exempt under this section of the lab standard (If you are under the lab standard)
This section shall not apply to:
Laboratory uses of hazardous chemicals which provide no potential for employee exposure. Examples of such conditions might include:
Procedures using chemically-impregnated test media such as Dip-and-Read tests where a reagent strip is dipped into the specimen to be tested and the results are interpreted by comparing the color reaction to a color chart supplied by the manufacturer of the test strip; and
Commercially prepared kits such as those used in performing pregnancy tests in which all of the reagents needed to conduct the test are contained in the kit.
On 12/4/2014 3:15 PM, Edward Miller wrote:
We are currently having a discussion among our biochemists that their DNA starter segments, DNA sequencing kits and other materials like that are not chemicals and therefore they should not fall under all of the inventory control and ordering controls we have in place for things like sulfuric acid or other more readily recognizable chemicals. Does anyone have any feedback on how the regulations view these types of items?
On Tue, Dec 2, 2014 at 2:18 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**keene.edu> wrote:
I am helping to organize a technical symposium for next June's ACS Northeast Regional Meeting in Ithaca, NY on the topic of Green Labs: Balancing Safety and Sustainability in the 21st Century Chemistry Lab. this is a similar topic to a symposium DCHAS sponsored in the San Francisco meeting last fall, which was quite successful.
The abstracts submission web site will open in January, but I wanted to start Northeast members of DCHAS thinking about submitting an abstract for this symposium. If you are interested in talking about new environmentally-friendly programs in your chemistry department or how lab sustainability considerations impact laboratory safety at your campus, please consider submitting an abstract. I'd appreciate hearing about your ideas before the holiday break so that I can send out reminders when the abstract submission process begins.
Let me know if you have any questions about this.
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
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