On Sep 8, 2019, at 7:20 PM, Samuella Sigmann <sigmannsb**At_Symbol_Here**APPSTATE.EDU> wrote:

Sounds like it could qualify as "Materials of Trade". 

The regulations that apply to MOTs arefound in 49 CFR Section 173.6. 

They include:• general knowledge of MOTs regulations;• quantity limitations;• packaging requirements; and• marking and labeling requirements.
The MOTs regulations do not require:• shipping papers;• emergency response information;=E2=80=A2 placarding; or • formal training or retention of trainingrecords.

https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/MOTS%20brochure%202007_10_02.pdf
Sammye

On 9/8/2019 6:26 PM, DCHAS Membership Chair wrote:

From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com> 
Re: CHO at museum asks for our help

A really nice CHO at an LA museum found that the conservation staff has plans to transport chemicals from the museum to offsite facilities where they would perform treatment on objects.  The kits would vary depending on the treatment needed, but most of the time the kits would contain acetone, isopropanol, toluene, xylene, acetic acid, mineral spirits.  The CHO is not familiar with the DOT and other regulations for transporting/labeling chemicals..  But he ran across Title 49 Part 173.4 Small quantities for highway and rail outlines and realized he could have some issues with this plan.

This is not an area I'm strong in and usually suggest a consultant. If any of you have this area nailed and could help, or if you know of a reasonable consultant to refer this to, the CHO can be reached at:

Carlos Aponte
Chemical Hygiene Officer
Los Angeles County Museum of Art
Conservation Center
5905 Wilshire Blvd.
Los Angeles, CA 90036

(323) 932-5899
CAPONTE**At_Symbol_Here**LACMA.ORG

Thanks to all,  Monona

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We, the willing, led by the unknowing, are doing the impossible for the ungrateful. We have done so much, for so long, with so little, we are now qualified to do everything with nothing. Teresa Arnold paraphrased from Konstantin Josef Jire=C4=8Dek (1854 - 1918)

 

Samuella B. Sigmann, MS, NRCC-CHO

Chair, ACS Division of Chemical Health & Safety, 2019

Senior Lecturer/Safety Committee Chair/Director of Stockroom

Chemistry

Appalachian State University

525 Rivers Street

Boone, NC 28608

Phone: 828 262 2755

Fax: 828 262 6558

Email: sigmannsb**At_Symbol_Here**appstate.edu

 

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