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From: Jeff Tenney <jtenney46**At_Symbol_Here**ATT.NET>
Subject: Re: [DCHAS-L] [EXT] Re: [DCHAS-L] Letter to the National PTA regarding the rainbow flame demo
Date: Oct 1, 2019 14:31 UTC
Reply-To:
ACS Division of Chemical Health and Safety
In-Reply-To: Re: [DCHAS-L] [EXT] Re: [DCHAS-L] Letter to the National PTA regarding the rainbow flame demo
Please remember under OHSA, 29CFR1910 (section 5 a), OSHA have the power to pursue penalties if the employer, school, does not supply a place free of recognized hazards. I would say an uncontrolled open flame would qualify. Not having an eyewash when handling caustics, could be another fineable offense. There are rules in place but the employers lack the knowledge to make sure they are being enforced and/or protections are in place.
This biggest problem has always been training and education. It would be nice if the ACS would set up a free program (maybe a small fee like 20 dollars a year) for school systems or educators to have access to training material when it comes to demos. (I know am pushing it to someone else to do) That would address how to perform the experiment safely, high quality videos of those that cannot be done safely in most high school chemistry labs. We do have a division of chemical education.
If OSHA would just fine one of these incidents then maybe that would wake some systems up to getting some training for the teacher of at least forcing a review of the demo before it is performed to see how safe it is.
Jeff
Sent from Mail for Windows 10
From: Harold Ingmire
Sent: Tuesday, October 1, 2019 9:56 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
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.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Anthony Noce
Sent: Monday, September 30, 2019 6:47 PM
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
Bigger is NOT better?
Says who?