From: "Melarkode, Ramesh" <rmelarkode**At_Symbol_Here**USGS.GOV>
Subject: Re: [DCHAS-L] Review of chemicals to be purchased--standard practice?
Date: Fri, 5 Aug 2016 18:15:20 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAOAWpPyHLbTQJT0C9MZUmp_ZOxKgWBZL9pB4p8L9VYHFdECR4g**At_Symbol_Here**

Neil & Janet,

I have to agree this appears to be a ridiculous request. But let me also try to approach your concerns from a slightly different angle / perspective, from an overall facility environmental compliance standpoint, my expertise. I am not sure if your facility (in this case, Univ as a whole) is subject to the EPCRA reporting. [EPCRA -- Emergency Planning and Community Right-to-know Act] It is regulated by USEPA under 40 CFR 370. It is an annual requirement (by Feb./Mar. timeframe) to report all hazardous materials stored / used on-site, that is above a certain threshold quantity. The threshold is tabulated by CAS No. and other identifiers, synonyms and is different for each chemical. Also, in another section of the same regulations, 40 CFR 313, toxic release inventory (TRI) annually by July 2nd -- all releases, spills to land, water, air emissions, hazardous waste disposal, etc. You may or may not be subject to the second part (TRI) depending on your facility. In addition, the OSHA regulations, 29 CFR 1910.1200 under the Hazardous Communications Program (commonly referred as HazComm) requires maintaining a similar inventory with proper labeling, matching SDS to the chemicals on hand, and other things, from a worker protection standpoint. These reports and documentations are subject to USEPA and OSHA unannounced inspections and citations, if not managed properly.

Given the title of your officer, Environmental, Health, and Safety may be responsible for both reports. Typically, copies of the purchase requests, SDS, etc. forwarded routinely to the EH&S Dept ought to be sufficient, so they can do their reporting. Did the Univ have issues in the past on the submittal of those annual reports? The reason for his asking "before and after" and with such scrutiny? Just a thought!


Ramesh Melarkode
Environmental Management Branch, MS-207
U..S. Geological Survey
12201 Sunrise Valley Drive
Reston, VA 20192

Tel.: (703) 648-7351
EMail: rmelarkode**At_Symbol_Here**

On Fri, Aug 5, 2016 at 5:25 PM, Neil Edwards <Neil.Edwards**At_Symbol_Here**> wrote:

That is absolutely ridiculous. It should be up to the department as to what chemicals to purchase, as long as they are stored and used properly. I suggest sending him the SDS and telling him that you need an answer within two hours because the chemical needs to be ordered today. The SDS that comes with the chemical should be exactly the same as the one you provided before ordering, if you are getting it from the vendor website; so I don't understand why he should be asking for a second copy.
In short, you give someone a little power, and well... you know the rest.

Neil Edwards
Laboratory Manager
Adjunct Associate Professor
Department of Chemistry
LIU Post
Brookville, NY 11548-1300
Email: neil.edwards**At_Symbol_Here**

From: "Rogers, Janet" <ROGERS**At_Symbol_Here**EDINBORO.EDU<mailto:ROGERS**At_Symbol_Here**EDINBORO.EDU>>
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU<mailto:DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>>
Date: Fri, 5 Aug 2016 20:10:56 +0000
To: <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU<mailto:DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>>
Subject: [DCHAS-L] SDS review of chemicals to be purchased--standard practice?

To All:

Our EH&S officer has decided that we have to send him the SDS for every chemical we are going to purchase so that he can review it before we are allowed to purchase the chemical. Then, he wants us to send him the SDS that came with the chemical.

Is this a standard practice? I can see reviewing SDS for very hazardous substances, but even for chemicals sodium chloride and sodium bicarbonate? I can understand his reviewing the SDS for substances we've never previously used on campus. However, I think he'll drive himself (and us) crazy if he looks over every single SDS every time we make a purchase.

I fought to get the administration to allow us to make purchases with a credit card so we could make purchases shortly before we used chemicals in class. This procedure let us order smaller quantities and has helped us reduce our inventory, since we no longer had to "over purchase", just to guarantee that we would have enough material for our classes should the purchasing paperwork get held up.

Please let me know what level of EH&S scrutiny of chemical purchases is considered standard practice at undergraduate academic institutions.

I look forward to your responses.

Janet Rogers, Ph.D.


Chemistry Department

Edinboro University

230 Scotland Road

Edinboro, PA 16444

phone: 814.732.1539

e-mail: rogers**At_Symbol_Here**<mailto:rogers**At_Symbol_Here**>

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