DCHAS-L Discussion List Archive

Dear CHAS, The Building Code rules here with the Fire Marshal and
building inspectors.  Those folks do not enforce any OSHA or EPA regs.

Janet Baum, AIA, Principal
Health, Education + Research Associates, Inc.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Gordon Miller
Sent: Monday, May 21, 2007 10:03 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] NFPA standards

Unfortunately, safety can be summarized by paraphrasing Mao ze Dong. 
He said "Justice grows from the barrel of a gun." Figuratively, 
safety grows from the barrel of a gun. The gun is enforcement. Fire 
Marshals can enforce NFPA45, etc. and they have significant 
enforcement authority.

NFPA IS regulatory with more certain enforcement, via fire 
inspections, than OSHA or EPA.


>
>
>Recently our Fire Marshall began a series of Lab Inspections,
>concentrating primarily on quantities of chemicals. This required all
>the researchers to provide an inventory for the labs,  which was not a
>problem, since one is required as part of the University's Chemical
>Hygiene Plan.
>
>
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>My question to the List is :     OSHA's Lab standard is
>performance-based, and Law;  EPA's RCRA regulations, while
prescriptive,
>have become institutionalized    because no one wants a Consent Order
>(speaking from experience).    NFPA 45 is not Law, yet seems to trump
>OSHA & RCRA, because Building Codes make it appear regulatory.
>
>
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>Even if a researcher manages his/her chemical inventory properly
>(labeling, segregating), and their hazardous wastes properly (labeling,
>segregating), it appears that the NFPA holds them to higher standards.
>Researchers are questioning this.   And even if they comply by removing
>some chemicals ,     they say they will just order more after the Fire
>Marshall inspection is completed.
>
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>Are any EH &S professionals finding this a problem?
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>________________________________
>
>
>
>________________________________
>
>Stefan Wawzyniecki, CIH, CHMM      NRCC-CHO      University of
>Connecticut  Chemical Health & Safety
>
>________________________________
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