From: Alan Hall <ahalltoxic**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] Waiver Form Example
Date: Fri, 4 Sep 2015 10:29:08 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAHFAP+7aeGwbyyXFbkvm=rmShLcz9CRtXs6r5_xgQp799NECYQ**At_Symbol_Here**

Et al,

As one (?the only?) Board Certified Medical Toxicologist in the group, let me toss in my 2 cents worth.

I started my professional career as a rural General Practitioner, went on from there to Occupational Medicine, trained in Anesthesiology (all general anesthetic cases are really controlled overdoses) ,served as a Flght Surgeon in the USAFR until retirement (with all the toxc and other hazards associated with Aerospace Medicine), was a Board Certified Emergency Physician for 20 years (with all the toxicology cases that involves), and now a Board Certified Medical Toxicologist for 30 years,I can state from personal experience that the average physician does not have the speciaized training or experience to deal with the issues presented here. This is not to disparage anyone; the majority of physicians are comeptent in their chosed fields and have a deepp and abiding caring for the well-being of their patients.

As pointed out, however, few would be able to decipher a complex SDS (and I remain highlyskeptical that the average SDS is worth more than the paper and toner it takes to print it). When Neal,Harry,and I did some Ask Dr. Safetys sessions on Reporductive Hazards in the Laboratory, there were questions all 3 of us could not really answer because of lack of data.

So, no, don't try to be antagonistic with physicians. It would be bettrer if such an approach is needed for the laboratory safety officer to do the literaure research, summarize what is known abut potential hazards, (dose-duration estimates if possible) and send that informatiion with the student to their physician with the sumarrized information. A collaborative effort will clearly be best.

And also include details aout what PPE is required, used of fume hoods or other safety measres, and as realistic as possible estimate of the actual potetential exposure/systemic absorption or local toxicity/injury,etc.

Recall that presence of a substance in a laboratory does not equal exposure and exposure does not equal toxicityy .Also keep in mind that "crying wolf" too often when there really is no hazard/risk, then when there really IS a wolf (jhazard/risk), warnings may be disregarded.

Alan H.Hall,M.D.
Medical Toxicologist

On Fri, Sep 4, 2015 at 8:13 AM, ILPI Support <info**At_Symbol_Here**> wrote:
Physicians offices are bombarded with requests for health/physical signoffs for sports etc. All of these forms look at the individual's overall health for a particular physical activity.

The vast majority are not experts in fields beyond their own. They can tell you someone with a peanut allergy shouldn't work in a peanut factory. But they are not industrial hygienists or toxicologists, and most of them have taken no chemistry beyond intro organic lab and in most cases that was 10+ years ago.

The only way most physicians could pass the test you propose would be to spend hours online searching for information (because he or she has no idea where to find it beyond Google or PubMed), and given their other time demands that's not going to happen. It's the equivalent to "gotcha" journalism, setting the target up for something they are almost certain to fail.

Even if the student came armed with an SDS stating that the material is mutagenic, there is no way the physician could accurately assess the *risk* given the nature of the experiment, facilities, PPE (glove selection, for example.), quantity, other reactants, and myriad other factors. Not to mention that the mutagenicity finding may not be relevant to humans.

And that's just for the SDS's where there is actual human health information. CAS has now cataloged 101,000,000 unique chemical substances and that list grows daily ( ). As we've discussed multiple times on the list, there simply is no health information on the vast majority of SDS's and OSHA does not require any testing when formulating an SDS. Moreover, SDS's are not meant for students who will typically engage in one short-time use, they are meant for people who are occupationally exposed to the material day in and day out - so the health information (if any) may not be relevant.

Finally, since your proposal involves adding something for the physician to flag, let's assume he/she focuses on that and nails the call. They may not then be bothered to look at the other compounds in the list that the student will actually work with. But the student may assume that all of the other ones were vetted and proceed with a false sense of security.

The bottom line is that this is a complex determination even for the best-informed people. It takes a team working together for the tough cases like pregnancy, and assessing the competency of a physician on the team is best done by interacting with them in a discussion rather than in isolation.

Rob Toreki

Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust. Visit us at
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

On Sep 4, 2015, at 7:05 AM, Ben Ruekberg <bruekberg**At_Symbol_Here**CHM.URI.EDU> wrote:

An ethical question occurred to me.
Assuming a student wishes to consult their physician regarding which experiments they should ask to be excused, would it be ethical to insert in the information an experiment which will not be performed but which calls for the use of a teratogenic, mutagenic or allergenic compound? If the physician fails to identify this "experiment" as proscribed, their competence to advise should be called into question. This could be valuable information. On the other hand, it involves deception.
Does this fall under the rubric of human experimentation without proper informed consent, taking the physician's time unnecessarily, or simply a bad idea?
Any thoughts, politely stated, would be welcome.
Thank you,

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