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Subject: Re: [DCHAS-L] GC/MS vial disposal?

Date: Sep 13, 2018 14:07 UTC

Author: Heather McCollor <mccollor**At_Symbol_Here**macalester.edu>

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Subject: Re: [DCHAS-L] GC/MS vial disposal?

Date: Sep 13, 2018 14:27 UTC

Author: Karla Torruellas <ktorruellas**At_Symbol_Here**E-ZWELD.COM>

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From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>

Subject: Re: [DCHAS-L] A pesticide question to boggle the mind

Date: Sep 13, 2018 14:08 UTC

Reply-To: ACS Division of Chemical Health and Safety

In-Reply-To: Re: [DCHAS-L] A pesticide question to boggle the mind

Demystify: 

I talked to an EPA compliance officer yesterday, and old pal.  He says there is absolutely nothing in the EPA regs that will work to protect our workers or stop the use of this product. (And the only OSHA rule might be the General Duty Clause, but you know how tough that would be.)  But as a chemist, he thinks our best possible route would be the fire regs since the stuff is potential flammable when suspended in air.  But that would only work for indoor locations.

He also is uncomfortable with this gap in the rules that allows pesticide chemicals to be used for non-pesticide uses when purchased generically.  For example, the snow product would result in vastly higher amounts applied to outdoor areas than would be allowed for metaldehyde if it were used as a pesticide.

So when Rob asked:  "So is it legal to sell chlorpyrifos if you market it as house paint, incense, or fabric softener?"   The answer probably would be "no" for house paint or fabric softener which would be a significant use in terms of volume and might come under a SNUR.  But for incense or any other low volume specialty use, the answer probably would be "yes."

Thank you for helping me think this through.  Just because I don't like the conclusion doesn't diminish my gratitude.


Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062
actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 


-----Original Message-----
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Sep 13, 2018 4:21 am
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind

Yes, but the use Monona has described is hardly NEW.  As she notes, it has been used that way for decades.  Does the SNUR still apply?  I suspect not.
 
 
Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Layman, Rachel
Sent: Wednesday, September 12, 2018 9:02 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind
 
Would this not apply here as well?  https://www.epa.gov/reviewing-new-chemicals-under-toxic-substances-control-act-tsca/filing-significant-new-use-notice
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of ILPI Support
Sent: Wednesday, September 12, 2018 8:38 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind
 
So is it legal to sell chlorpyrifos if you market it as house paint, incense, or fabric softener?  Need an EPA law expert here to chime in.
 
Rob Toreki
 
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Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at http://www.SafetyEmporium.com
esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
 
 
On Sep 11, 2018, at 3:59 PM, Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM> wrote:
 
Have I missed something?  The use Monona describes is clearly not for killing or controlling pests.  How, then, is it subject to EPA pesticide regulation?
 
I know, that is bureaucratic silo-ing, but isn't that the nature of bureaucracy?
 
 
Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of ILPI Support
Sent: Tuesday, September 11, 2018 1:06 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind
 
OMG and then some.  See https://www3.epa.gov/pesticides/chem_search/ppls/005481-00091-20120214.pdf and scroll down to the part where it says "Metaldehyde is a systemic toxin. There is no antidote. The following instructions are meant for laypeople. There is no home treatment. Exposed individuals and animals should receive emergency care as quickly as possible."  And keep on reading from there.
 
Given that it is classified by the U.S. Environmental Protection Agency (EPA) as a Restricted Use Pesticide (RUP), I'd call in a HazMat response to the film location and tell them to send the manufacturer the bill.  And ask a class action lawyer for a referral fee.
 
Who the heck is selling this pesticide for such egregiously unlawful use? 
 
Report the violation here: https://echo.epa.gov/report-environmental-violations   See also https://www.epa.gov/pesticide-incidents/how-report-spills-and-environmental-violations  I wonder if there are financial rewards for reporting incidents like this?
 
Rob Toreki
 
 ======================================================
Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at http://www.SafetyEmporium.com
esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
 

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