Yes, very appropriately stated the fine balance between theory and practice, the users and the regulators.
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu]On Behalf Of Lawrence Tirri
Sent: Monday, August 8, 2016 1:43 PM
Subject: Re: [DCHAS-L] SDS review of chemicals to be purchased--standard practice?
I sat back a few days following the responses and arguments both pro and con. Valid points have been expressed by both sides of the issues.
Having served on both sides, i.e., as a Founding Director of EH&S as well as a tenured member of the academic faculty, I would like to offer my perspective. Since I have not interacted with the EH&S Director at the institution that was referenced in the original post, I can't say anything about his agenda or why he is behaving in this manner. I can say that if he does not communicate with the faculty and researchers or take the initiative to sit down with them and work out a solution beneficial to everyone, he will alienate faculty and researchers and find them at the least, uncooperative.
In my opinion, administrative issues such as inventory control, storage, regulatory limits, etc, are secondary. The primary issue that must be addressed is if the person(s) using any chemical has(have) the necessary training and equipment to use the chemical safely.
All the other administrative issues could be worked out by listening to each other and arriving at a compromise. (OMG, what a novel idea !!!) The EH&S Director and his staff, must work out procedures such that they will have one condition that must never be compromised, i.e., make certain that hazardous chemicals are used safely.
This is what I call the "Safety Paradigm" where EH&S staff serve as resources and collaborate with chemical users to help them work safely. It has been my experience that as soon as the EH&S staff deviate from this paradigm, they set up an adversarial relationship with those whom they are supposed to serve and keep safe.
Dr. Larry Tirri
Department of Chemistry and Biochemistry
University of Nevada, Las Vegas
Las Vegas, NV 89154-4003
"The only two certainties in life are change and death. If we choose to embrace change and become part of the process, we leave behind a legacy that will live on forever, or you may choose the alternative."
On Mon, Aug 8, 2016 at 7:19 AM, Dan Kuespert <dkuespert**At_Symbol_Here**jhu.edu> wrote:
Your question seems to have drawn a wide variety of answers. Is this mandate limited to the chemistry department? While qualified chemists might be expected to be able to evaluate the hazards of the chemicals with which they are working—although remember that Sheri Sangi was a “qualified chemist,” not a student—as Monona pointed out, the artists aren’t. Neither, in my experience, are the mechanical engineers or physicists, who are often convinced that they don’t use chemicals, even as they wash parts in MEK.
At my institution (which is a Research I university, not an undergraduate institution), the onus of reviewing the hazard is on the PI, but the PI is supposed to ask for permission and register any “highly hazardous chemical,” which is defined as a superset of the Lab Standard’s definition. SDSs are maintained electronically using a commercial database, so you really don’t have any excuse not to pull one for an unfamiliar chemical before ordering.
Decentralized purchasing & control of the chemical inventory does lead to problems: it becomes difficult to ensure, for example, that you are below fire code limits on flammable materials unless each lab is a separate fire control area. (Which they usually aren’t, especially in buildings more than a century old.)
However, we have another branch of the institution that does about $1B (yes, “billion” with a “b”) in US Government work annually. Their researchers and EHS people tell me thatif it is a new chemical to the site (meaning, it’s not in the site’s chemical inventory), then you are required to obtain an SDS and get EHS’s sign-off on the purchase. On the part of EHS, they commit to rapid turnaround of such paperwork. As another commenter mentioned, what they’re looking for is peroxide-formers, reactive compounds, Homeland Security Chemicals of Concern, or purchase amounts that are likely to take the site over the threshold for various regulations such as Process Safety Management. There’s no outrage over the policy—I asked a lab manager why he didn’t object, and he said, “that’s just the way we do things here.” He saw it as a layer of protection instead of an administrative burden.
There are legitimate reasons for EHS to want to see the SDS beforehand. I understand, as an academic and former industrial research engineer, the desire to Get Things Done and have the chemicals as quickly as possible, but I also, as an EHS professional, understand the desire to maintain compliance and also to perhaps head off instances of personnel using chemicals far too dangerous for their skill level. I do not, however, see much need for EHS to review SDSs again for chemicals already in your inventory and reviewed. (If they’re maintaining the campus chemical inventory, though, you’ll need to notify them so that they can keep it up to date.)
It doesn’t appear that EHS has the best relationship with the academic departments at your institution. It might be worth your while to get a neutral party to broker a meeting with both EHS and Chemistry to vent frustrations and come to a workable compromise. At our institution, we have trained mediators who can be called in; if yours doesn’t have such a thing, someone from the Provost’s Office or Office of General Counsel might suffice. I would suggest working out a system similar to that I mentioned above: get a sign-off from EHS if it’s something that’s not on the inventory. After setup, there’s no additional work for common chemicals like NaHCO3, and you benefit from a reviewer with a different skill set than yours for new chemicals.
On Aug 5, 2016, at 16:10, Rogers, Janet <ROGERS**At_Symbol_Here**EDINBORO.EDU> wrote:
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 itbefore 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.
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