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From: Ralph Stuart <rstuart**At_Symbol_Here**UVM.EDU>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
Date: Feb 18, 2011 01:17 UTC
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Message-ID: <legacy-2011-20110217p@ilpi.com>
In-Reply-To: <588132.55116.qm**At_Symbol_Here**web111405.mail.gq1.yahoo.com>
> >I advise my clients during inspections to replace any chemicals older than a year. That helps eliminate the inherently waste-like, speculative accumulation, etc practices EPA folks like to cite. I agree that that is good advice, but we advise someone who has "perfectly good" chemicals that are more than a year old that they want to keep to label them with an inspection date so that the EPA concern about their inherently waste-like nature is rebutted. We recommend that such inspections happen annually to demonstrate prudent approach in chemical inventory management. This has worked for us in some cases during a couple of different inspections, although there were some arguments that we lost on the issue as well. - Ralph Ralph Stuart, CIH Environmental Safety Manager University of Vermont Environmental Safety Facility 667 Spear St. Burlington, VT 05405 rstuart**At_Symbol_Here**uvm.edu