From: Bruce Van Scoy <bvanscoy**At_Symbol_Here**TWC.COM>
Subject: Re: [DCHAS-L] Examples of Control banding and Chemical Safety Levels
Date: Tue, 3 May 2016 19:50:03 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 000701d1a596$83abd910$8b038b30$**At_Symbol_Here**

I was thinking on the health exposure classifications based upon the GHS
requirements. The EU's Reach regulations are so far ahead of us in doing so
from what I have encountered. Shouldn't we be considering both the observed
incident rates along with the inherent process based exposure hazards? I
had not compared/contrasted the specific control methodologies and
differences to chemical vs. biological control banding. What are they?
Sometimes I think it is better to return to our roots of recognition,
evaluation and control (elimination is often not a scientific option).
Regardless of the chemical or biological control banding approaches used, it
would be nice to have recognized sources, e.g., chemical and biological
similarly classified regarding evaluation and control methods. If the
control system(s) employed protect those being exposed from a BSL4 agent,
those same systems should easily protect against a highly carcinogenic,
teratogenic or mutagenic compound. I may be wrong and open for discussion,
but I think we need to emphasize identification, quantification (when
available) and engineering controls.
P.S. I only mention the quantification because today I ran into a chemical
compound that I need to protect against with a low recommended PEL/STEL with
no known sampling/analytical method, not unusual. But doesn't the same
exist for biological agents? Try to define an effective dose for a
biological agent, let alone a validated sampling/analysis plan; mostly all
you can find is a significant increase in the infectivity rate of an exposed
population, e.g., laboratory workers, with no known source of exposure. Is
that being effective at controlling, reducing or eliminating exposures?

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of
Stuart, Ralph
Sent: Tuesday, May 3, 2016 9:47 AM
Subject: Re: [DCHAS-L] Examples of Control banding and Chemical Safety

> Does the group think it appropriate to apply the concepts to particle
size, based upon aerosol deposition or can it be expanded to the
classification of exposures based upon GHS classifications?

The challenge I see there is that there are multiple hazards with chemical
vapors beyond those controlled by ventilation. For example, corrosive
liquids or those with oxidizing capability are GHS classifications that
wouldn't be controlled by ventilation. Are you thinking in terms of the
health hazard classifications within GHS?

> >I would be very curious if the members have reviewed and compared control
> banding with the processes identified as generating aerosols from the

This brings up an interesting question: is it better to build a control
banding scheme around the inherent hazards of an operation or around the
observed incidents when performing the process. For example, many of the
aerosol sources identified in this document are process or behavior based
rather than inherent to the hazardous material. One difference is that
biosafety control banding uses a different approach to chemical control

Thanks for your comments.

- Ralph

Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College


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