From: Don Abramowitz <dabramow**At_Symbol_Here**BRYNMAWR.EDU>
Subject: Re: [DCHAS-L] Why are QC/Qa labs not covered by the Lab Standard?
Date: Thu, 4 Feb 2016 10:50:14 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 1841901159.71825088.1454601014600.JavaMail.root**At_Symbol_Here**zimbra-mailbox
In-Reply-To


I can't help but wonder if there wasn't some push-back from the manufacturing sector during the comment period to narrow the scope of the then new laboratory standard as much as possible.  That info might be in the public record, if one cared to do the research.  One consideration may also have been that QA/QC labs are often small operations that employ technicians repeatedly running the same tests/analyses, and are not necessarily staffed by professionals with advanced degrees.

                                                            Don

Donald Abramowitz
Environmental Health & Safety Officer
Bryn Mawr College
Bryn Mawr, PA



All -

 

I've looked at the lab standard directly on the OSHA site and also at the comments from 1991 memorandum from Patricia Clark to John Miles.

 

1.       QC/QA labs are not covered under the lab standard, because they support production.

a.       Yet, they use laboratory scale quantities of reagents, which are also very often different from the materials used in production.

b.      These lab people experience the same scales of exposure, waste management and handling situations as those in independent labs, not just like their production line coworkers.

 

2.       Bench-scale operations that look at substitutes for processes - because they are considered R&D and not QC/QA

a.       Yet for sure they support production.

b.      Usually these chemical quantities are larger than in QC/QA.

c.       The reagents may or may not be different from what is used in production, but the scale of use is larger than in any lab, certainly a quality lab even if considered "lab-scale."

 

3.       Repetitive procedures in workplaces which are not production sites

a.       Even a small amount produced for subsequent scale invalidates coverage under lab standard. This I understand,

b.      These are repetitive just like QC/ QA. They are also unlikely to change. So why are they covered by lab standard?

 

I do not understand the point of the distinction. The end result would be to bind QC/QA labs to the OSHA regulations for large production level quantities of chemicals.

 

Can anyone enlighten me?

 

 

Sincerely.

 

Ujjvala (Vaiju) Bagal
Quality Scientist/QM Key User/Chemical Hygiene Officer


EMD - Living Innovation


EMD Performance Materials Corp. 110 EMD Blvd. Savannah, GA 31407 USA
Phone: 912-966-4421 Fax 912-966-5917
Email:   vaiju,bagal**At_Symbol_Here**emdgroup.com -
 www.emd-pm.com
EMD Performance Materials Corp. is a subsidiary of Merck KGaA, Darmstadt, Germany

 

 

This message and any attachment are confidential and may be privileged or otherwise protected from disclosure. If you are not the intended recipient, you must not copy this message or attachment or disclose the contents to any other person. If you have received this transmission in error, please notify the sender immediately and delete the message and any attachment from your system. Merck KGaA, Darmstadt, Germany and any of its subsidiaries do not accept liability for any omissions or errors in this message which may arise as a result of E-Mail-transmission or for damages resulting from any unauthorized changes of the content of this message and any attachment thereto. Merck KGaA, Darmstadt, Germany and any of its subsidiaries do not guarantee that this message is free of viruses and does not accept liability for any damages caused by any virus transmitted therewith.

 

Click http://www.merckgroup.com/disclaimer to access the German, French, Spanish and Portuguese versions of this disclaimer.

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.