DCHAS-L Discussion List Archive
Date: Thu, 17 Feb 2011 19:35:02 -0500
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From: Ralph Stuart <rstuart**At_Symbol_Here**UVM.EDU>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
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
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