From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Nickel Carbonyl
Date: Sat, 15 Aug 2020 18:05:08 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 88F8B553-AB31-48C7-A564-279643CF167C**At_Symbol_Here**

At a very low inventory (150 lb) of nickel carbonyl, you are into the Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119) and Risk Management Plan (40 CFR 68) regulations. With good reason. The various hazmat provisions of the International Fire Code (treatment systems for ventilation effluent, etc.) will kick in as well, no doubt, but my copy of the IFC is in an office I've been to once in the last six months, so I can't easily check.

Dan Kuespert

Daniel Reid Kuespert, PhD, CSP
11101 Wood Elves Way
Columbia, MD 21044

On Aug 15, 2020, at 15:21, davivid <davivid**At_Symbol_Here**WELL.COM> wrote:

I have a client in California who is considering using a process that uses nickel carbonyl. I have made them aware of the extremely toxic nature of this compound. The only reason they are considering it is that it solves a problem that would be very difficult to achieve any other way. My question to the community is this: what, if any, specific regulations are there regarding the use of this compound?

Thank you

Dave Lane
Clavis Technology Development

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