Thank you - very interesting problems in industries I am not familiar with (arts). Maybe the liability insurance companies for schools should step up a bit.

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Monona Rossol
Sent: Tuesday, October 01, 2019 9:21 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] [EXT] Re: [DCHAS-L] Letter to the National PTA regarding the rainbow flame demo

You have never stumbled across statutes specific to education under OSHA because there aren't any.

EPA rules are usually industry- or process-specific and they have a bunch of rules specific to education.

But OSHA just divides their standards between Construction and General Industry (not counting Maritime). School employees do work that is usually under General Industry standards unless those employees are engaged in defined construction activities such as renovating, painting or decorating.

It's a rather clumsy system actually. And the people I deal with in both education and the theatrical and film industries have great difficulty in accepting that they are not "special." They are just another ordinary industry under OSHA and the rules all apply to them. They have trouble seeing the front lip of the stage as a fall hazard under General Industry and the construction of a set as coming under the Construction standards. Or they have difficulty understanding that the workers are under the Construction standards while building the set, but they have to design and build the set to meet General Industry safety standards because the Actors, set dressers, etc., who will access the set are General Industry workers.

So to with education. Most of the work comes under General Industry such as hazcom or lab standard, PPE, materials handling, etc. And there are the students. Young students do not come under OSHA so that leaves some interesting gaps filled usually by strict liability. College and/or grad students in some schools are under workers comp and OSHA, but often are not, again leaving it to liability.

But in theater and film, we have paid "workers" who are infants, young children and/or older children. Some of the OSHA rules designed for adults are applied to them and that is often a big problem for us, especially the PELs.

I can think of better ways to do this, but I've noticed no one has put me in charge.

Monona

-----Original Message-----
From: Harold Ingmire <hingmire**At_Symbol_Here**WHIPMIX.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Oct 1, 2019 8:36 am
Subject: Re: [DCHAS-L] [EXT] Re: [DCHAS-L] Letter to the National PTA regarding the rainbow flame demo

Are there any regulatory standards for education processes on safety? I have dealt with OSHA and DOT for decades, but never stumbled across statutes covering education specifically.

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