From: Melissa Charlton-Smith <melissafcsmith**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] SDS review of chemicals to be purchased--standard practice?
Date: Sun, 7 Aug 2016 14:02:04 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CALn8UKDDMf_ZEoJcHUkZ+hhU7rX6pdLptu-y5HQ8f-+RT=5Qzw**At_Symbol_Here**

I don't think "overwhelming the EH&S Officer" is the way to go. That just shows an unwillingness to participate in the safety culture, even if the requirements appear ridiculous. Having been a CHO for a very long time, in a small higher ed chemistry department, I understand those "last minute" orders, and the need to get them quickly for class next week. One thing we developed was a standing list of "regular" orders that we know will be required throughout the year and sync them with the lab syllabus so that the compound purchase order request would have enough time to go through the review, purchasing and shipping process in a timely manner. Our minimum Request to Receiving time was 2 weeks. Unfortunately this process requires planning, forethought, and organization.

I also completely understand the frustration of what appears to be pre-purchase approval overkill.. Yes, it is to some extent overkill, but it could also be, as someone else suggested, that EH&S is not trying to make your life more difficult, but rather to organize something on their end. Request a meeting with the EH&S officer, ask WHY? Explain your concerns that you are trying to downsize and don't want to purchase large quantities at the beginning of the semester, or academic year, but to purchase in small quantities as needed.

Now, If the instructor is not the one who is in charge of ordering the compound, then whomever IS in charge, needs the time to push the request through the process. If you don't want to keep chemicals in storage until needed, and want to purchase as demand requires, then you have to take into consideration the purchasing process and the time involved.

I would certainly consult with the EH&S officer as to why something like the purchase of the relatively low hazard sodium bicarbonate should be reviewed since it is a common academic lab chemical and tends to be purchased very frequently, or in bulk. Perhaps you can work out an agreement that certain compounds are "pre-approved" and purchased as needed with the pcard, such as the sodium bicarbonate, and arrange for the SDS to be sent to the EH&S as soon as the compound arrives. Also, arrange to notify EH&S whenever one of the pre-approved compounds is ordered. However, you might then also need to accept the EH&S officers need for approve any new compounds that have not previously been on-hand. The EH&S officer needs to know if the storage need of the chemical are on hand or if special arrangements are needed.

By the way, someone else mentioned that it is required that the manufacturer SDS of purchases be kept on file (actually a record of the compound must be kept on file for 30 years and the SDS is considered an acceptable record by OSHA), so I completely understand the EH&S wants the SDS. In fact you should consider photo-copying it for an "on-hand" copy if the original hard copy will be any distance from the storage and use locations. Alternatively, have an available online SDS library of compounds based on the chemical inventory (but hope that you don't have a power outage at the wrong moment). It does little good if an incident occurs and the SDS is on file in the EH&S office in another building, or a locked office. We sent photocopies of all SDS for in-use chemicals with the preps when they went out to the labs then retrieved the SDS after the prep was used and returned. If you have a lab manager/coordinator, who is in charge of setting out preps and retrieving them after use, it wouldn't take much time to have them include a photocopy of the SDS.

Anyway, just my perspective from several sides of this fence. I am a CHO and EH&S officer, and have been a lab instructor, lab manager, lab coordinator, the chemical requisition person and a prep supervisor.

Mel Smith

On Fri, Aug 5, 2016 at 7:13 PM, Tambasco, Aniello <aniello.tambasco**At_Symbol_Here**> wrote:

Hi Janet,

I feel your pain about battling administration to get a pcard for chemicals only. When we moved into a smaller space, we wanted a credit card just for chemicals ,to order on demand. The standard po process time was one week and tempers always flared.So after much convincing and begging we were granted a pcard.
The situation you are dealing with is ridiculous and that safety officer is on a power trip. I think this occurs when an individual feels threatened. This is also a waste of paper and time. This also occurs when an individual does not have a chemistry degree but had training through certificate programs.
The thing I would do is send him all the sds he wants plus more. I would send him certificates of analysis as well. The best trick here is overwhelm him and trust me he will get tired.He does have the right to know, so give him ALL the information. Play the game and they will get the picture. Best wishes and good luck.

Aniello Tambasco,MBA
Lab Technician and Assistant
Wilkes University

On Aug 5, 2016 4:56 PM, "Rogers, Janet" <ROGERS**At_Symbol_Here**> wrote:
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**

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