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I assume this was under TSCA. Does Baylor have commercial chemical activity? Are you working on chemicals that you hope may eventually be commercialized? If so, there is a minimum amount of review and documentation required to qualify for the R&D exemption for new chemical substances premanufacture notification. See EPA's site: http://www.epa.gov/opptintr/newchems/pubs/randdexemp.htm Requirements depend on who's doing what where. Georjean Adams >Hello, > >My name is Karen Humphrey and I'm the safety officer for Baylor's >Chemistry Department. I'm trying to sort out the violations we >received from an EPA audit that was done recently. One of the >violations that we received was for not having the proper >documentation for new chemicals made by our research groups involved >with synthesis. > >Do any of you have experience with the documentation required for >newly synthesized chemicals? All of the chemicals are for research >and development purposes, and all are in small quantities. >According to the regulations, as I understand them, we have to >provide notice of health risks that may be associated with exposure >to these newly synthesized chemicals. But how? Do we need to >generate some kind of MSDS, or is there a labeling system that is >used? > >Thank you in advance for your help. > >Karen Humphrey -- EHS Strategies, Inc. - enabling organizations to meet their EHS vision http://ehsstrategies.com 651-204-3371