From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Subject: Re: [DCHAS-L] Required Training?
Date: Wed, 12 Dec 2018 12:55:26 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 5578732A-DEA7-4078-AFB0-3BACC96BAB61**At_Symbol_Here**
In-Reply-To <85fa2e18ecae45c5873ba7c9aca1aefd**At_Symbol_Here**>

Thanks for asking these questions. They have come up in several other conversations I've had over the last month and are not easy to answer.

> >*1. Is there any OSHA-required training for chemistry lab coordinators who work with chemicals in an academic setting, preparing labs, helping supervise labs, and preparing chemical waste for disposal companies?

No, OSHA does not have specific training requirements for chemistry lab coordinators. OSHA requires the employer to provide appropriate training to their employees.

I would note, however, that OSHA is not the only regulatory agency whose rules can impact chemical work in the academic sector. EPA regulates waste disposal issues and DOT has training requirements for people who send and receive hazardous chemicals. These requirements are not coordinated in any way, so separate trainings can be required for these different regulatory functions or in different jurisdictions. For example, here in NH, Large Quantity Generators of hazardous waste are required to have someone with Hazardous Waste Coordinator Certification training from the state annually. This is an unusual requirement; I don't know if any other states have this requirement.

> >*2. If so, what is required?

It depends on where you are, what chemicals you are working with, what you are doing with them, and how much you have. Figuring out the regulatory requirements applicable to a chemical is the responsibility of the chemical's owner.

>*3. Are faculty, based on their degrees in Chemistry, exempted from any such requirements?

No. I don't know of any government agency that regards chemistry degrees (or legal degrees for that matter) as adequate training in chemical regulations. Again, it's up to the owner of the chemical to assure that the people who work with that chemical have appropriate regulatory training for that jurisdiction.

I wonder if anyone else on the list knows of any degrees that include chemical regulation training within their educational program? The formal courses I have attended on these topics have all been offered by consultants in the field or by the state of New Hampshire. The reason I ask is that I am helping to organize an ACS meeting in 2019 that will include discussions of how chemists might learn about their requirements as part of their education.

Thanks for any information on this.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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