From: Michael <mabuczynski**At_Symbol_Here**HOTMAIL.COM>
Subject: Re: [DCHAS-L] CHO at museum asks for our help
Date: Mon, 9 Sep 2019 14:07:26 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: DM6PR05MB6314539E213745D7171724D9ABB70**At_Symbol_Here**DM6PR05MB6314.namprd05.prod.outlook.com
In-Reply-To


The MOT was put in place to provide for businesses for example Painters who can transport a variety of paints and solvent over the road but in small quantities. Anyone availing themselves if the MOT DOT exemption should have copy of the reg in their vehicle and be able to have firsthand knowledge of the reg if stopped en route. I need to search my archives for the short form that I required the R&D chemist to have with them when transporting chemicals between site and attach it  for you

Mike Buczynski
Global Manager Haz Com and Product Stewardship
Johnson Controls Intl


On Sep 9, 2019, at 6:37 AM, Brenda Baney <b3**At_Symbol_Here**bcubedconsulting.com> wrote:

Good catch.  There might be a lab or R&D exclusion in the transportation, like DOT with CFR49.  They may want to know volume, and who will be handling.

On Sun, Sep 8, 2019 at 7:19 PM Harry J. Elston <harry**At_Symbol_Here**midwestchemsafety.com> wrote:
Monona - See if they qualify under the "Materials of Trade" exemptions in 49CFR173.6.

The ACS Committee on Chemical Safety had a whitepaper on it but evidently they have been scrubbed from the website.  I will send it to you off-list.  If it's useful, pass it on.

Harry

On Sun, Sep 8, 2019 at 5:28 PM DCHAS Membership Chair <membership**At_Symbol_Here**dchas.org> 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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--
++++++
Harry J. Elston, Ph.D., CIH
Principal, Midwest Chemical Safety, LLC

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Brenda B. Baney
B Cubed Consulting, Inc.
4068 Overlook Trail Dr.
Roanoke, VA  24018
+1 (540) 206-2379  tel.
+1 (765) 860-3481  cell

Company site:  www.bcubedconsulting.com

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