From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**>
Subject: Re: [DCHAS-L] New Publications from ACS Committee on Chemical Safety
Date: Sat, 20 Aug 2016 13:21:45 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: E42D7BCF-53D3-4822-81A8-02BA166BC2F1**At_Symbol_Here**
In-Reply-To <156a357c3f4-840-6d63**At_Symbol_Here**>

> > I need to convince a major university to cease requiring their art faculty to do risk assessments.
> >I certainly will use these ACS guidelines to help make my case about what should be included in the training, but any additional ammunition from you people, especially from EH&S people with jurisdictions that include art departments, would be appreciated.
I find this a fascinating question, particularly in the context to this week's discussion of peroxide forming chemicals. I have heard similar concerns from academic chemists when faced with this kind of request from the EHS office. Please bear with me as I try to flesh out that connections.

In the peroxide discussion, it was pointed out that this concern is very specific to the chemistry involved. This is not particularly useful information but for those of us in the EHS role, because we are not in a position support the variety of situations we are asked to help with. For example, we often find chemists looking to us for specific EHS advice, often after a unexpected experience with a published method from the chemistry literature.

Recent developments have demonstrated that the institution is expected to provide training and oversight that supports safe lab work using very specific lab techniques. This often means that people using those techniques need to help us with EHS responsibilities understand how to provide those services in a transferable, scalable and sustainable way because once the questions addressed in one campus lab, the institution will be expected to support its safe use across campus. Such a partnership between the lab staff and EHS staff is a sign of the generative safety culture that the National Academy of Sciences describes in its "Safe Science" publication.

The art department question is the flip side of this question; the people working with the materials of concern are seldom provided professional education or training that supports awareness of the chemical risk assessment and management process. (I'm fortunate that our printmaking faculty member is a firefighter as well, so he understands basic hazmat concepts and is willing to apply them in his studios.) In these cases, I think that the EHS staff has to take the lead in identifying resources that can support best chemical safety practices. Given that we are usually hired for our expertise on other topics (often regulatory requirements and relations), resources external to the institution (i.e. art safety literature and consultants) will be necessary to support this work.

In my experience, the common challenge in these two use cases is that the purchase price of the hazardous materials is often the end of the institutional oversight process, both for the chemists and artists in academia. And the available EHS resources are not in a position to make up the gap between that cost and the operational costs of using the materials.

Thanks for a very interesting question.

- Ralph

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


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