From: Info <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Stockroom Security
Date: Thu, 11 Aug 2022 12:46:38 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 514EB148-2D7A-4A0C-BF03-15F23AABA99E**At_Symbol_Here**ilpi.com
In-Reply-To <74e57e07-832c-4d26-8809-156a66623673**At_Symbol_Here**email.android.com>


A link with some reading: https://www.ncbi.nlm.nih.gov/books/NBK55862/ 

Chemicals of concern are a big part of this: https://nap.nationalacademies.org/resource/12654/Chemical-Safety-and-Security-Final.pdf  (note all the DHCAS members on that second page!)

OSHA recommends the following, but of course the chair no doubt considers every faculty member with a key as controlled access: "(o) Chemical storage and handling rooms should be controlled-access areas. They should have proper ventilation, appropriate signage, diked floors, and fire suppression systems." https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450AppA 

Some issue I would raise include:

1. Record keeping and inventory. It will go to hell with just about anyone able to walk in anytime. This is especially true if you have chemicals of concern.

2. Under the HazCom Standard, employees are to be trained on the chemicals in their workplace, not just have the Safety Data Sheets available. The standard is mushy on this, allowing training on categories of hazards or specific chemicals, but nonetheless, one can see an employee potentially being exposed to a substance they have no training on, a violation of the Standard: http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(h) 

3. What is the policy on working alone? Working in a chemical stockroom alone on a night or weekend is as risky as a lab. The work alone policy *must* extend to the stockroom if this access is granted.

On the flip side, as a former faculty member, I can empathize. It's 7 PM or a Saturday morning and you realize there is the one thing you need in the stockroom that will let you NOT waste the rest of your day.  So maybe there is a middle ground to be achieved. Or maybe it's time for a key card access system, which is more secure than people randomly having keys that they can lose or lend to people. An overlooked issue with standard keys is former employees - whether fired trying to obtain chemicals they shouldn't.  BIG security issue there.

Probably some more stuff to add, but my day job intrudes once again!

Rob Toreki


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On Aug 11, 2022, at 11:51 AM, Richard Palluzi <000006c59248530b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:

Many states require registering (perhaps not the right word) chemical equipment that could be used in the drug trade. My experience is that what is or is not included is a bit hit and miss but balances and a lot of distillation type vessels were on the list. However the rules only required you list the site they were on, not the room so using that argument for keeping a closed stockroom may be weak 

I will note that when we closed our open stockroom and required a sign out, usage decreased significantly for all items even those for which I can conceive of no use for outside a lab. Mostly we believed it forced people to look around in their drawers before just running out to get something new. People saw what you checked out and started questioning some amounts. (one person was encouraged to clean glassware rather than making everything a one time use for example!)

On Aug 11, 2022 11:16 AM, James Kaufman <jkaufman**At_Symbol_Here**LABSAFETYINSTITUTE.ORG> wrote:
Here's a question that I received and would like the feedback and suggestions of the listserv.  Thanks ... Jim 

I am the lab/stockroom manager for Chemistry and have maintained a secure stockroom now for the past 10 years. We have a new department chair and he wants to give access to all permanent, visiting, and adjunct faculty. I feel that this is a mistake but have to give evidence to support my reluctance of open access. Is there any regulations that I can quote about securing the stockroom? I know at one time Homeland Security sent an e-mail to our CPO and other CFOs about securing these areas. Any assistance you can give me would be greatly appreciated.



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