From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] Interpreting NFPA 45 Section
Date: Wed, 10 Apr 2019 16:43:12 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: E4F4E334-6BB6-462C-9DEE-87EE97866D42**At_Symbol_Here**

At the FAA, of all places, "What's the only word that means mandatory? Here's what law and policy say about "shall, will, may and must.":

And also 

You can read about the evolving opinion of whether "shall" = "must" (short answer: no) at those sites.

My suggestion to you is that you tell your clients that it clearly says "shall" and doesn't say "may" or "optionally".  Which gives you the imprimatur that you're talking about even if ooodles of legal experts can't figure it out themselves!  The restated version of that is, of course. W.C. Field's famous quote "If you can't dazzle them with brilliance, baffle them with b*******"

Rob Toreki

Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at
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Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

On Apr 10, 2019, at 4:12 PM, Margaret Rakas <mrakas**At_Symbol_Here**SMITH.EDU> wrote:

Folks--I would appreciate your help with making sure I interpret this section of NFPA 45 (2019) correctly-"Experiments or demonstrations that involve or produce hazardous quantities of fumes, vapors, particulates or gases SHALL (my emphasis) be performed in a chemical fume hood or other ventilation device, including demonstration hoods or other devices that meet the requirements of 2.1.1 of  ANSI/AIHA Z9.5..that is, able to capture the materials being evolved."

In the next section (, experiments performed outside of a fume hood are discussed in terms of using a protective shield or keeping viewers at least 10 feet away.

My reading is that because SHALL is used in, ALL experiments involving hazardous quantities of fumes, etc. MUST occur in a fume hood or other containment device.  (Section is referring to demonstrations that DON'T involve hazardous quantities of fumes, etc).

1) Am I correct in my reading?

2) Would moving a 6 ft Rubens Tube, which requires flammable gas in order to produce the demonstration, to an outdoor setting with viewers 10 feet away meet the spirit of  Or would NFPA 160 come into play? [If you haven't heard of this, google "Rubens tube" or "flame tube"-- there's some interesting Youtube videos]

As much I enjoy Youtube for catching up on stupid cat videos, SNL skits and the like, I really hate it at work....

Many thanks for your thoughts-don't know what I'd do without this group--totally worth my ACS dues several times over!

Margaret A. Rakas, Ph.D.
Manager, Inventory & Regulatory Affairs
Clark Science Center
413-585-3877 (p)

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