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Subject: [DCHAS-L] telephone requirement question

Date: Oct 19, 2022 18:03 UTC

Author: Burgmeier, Sally <sallyburgmeier**At_Symbol_Here**AUGUSTANA.EDU>

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Subject: Re: [DCHAS-L] [EXTERNAL] [DCHAS-L] telephone requirement question

Date: Oct 19, 2022 18:49 UTC

Author: Snyder, Brenda K <Brenda.Snyder**At_Symbol_Here**UTOLEDO.EDU>

From: Ralph Stuart <ralph**At_Symbol_Here**RSTUARTCIH.ORG>

Subject: Re: [DCHAS-L] telephone requirement question

Date: Oct 19, 2022 18:12 UTC

Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>

Message-ID: <415E84F6-786F-4CAD-B3F5-408DAEE06BE3**At_Symbol_Here**rstuartcih.org>

In-Reply-To: <CABR7N0RqCTdiG8S7_NhdRNnZQ=LYD6hSMPr=+L=V5_9tqR7LWw**At_Symbol_Here**mail.gmail.com>

Demystify: 

> >Is a personal mobile phone considered an adequate communication device for a worker in a chemistry lab or chemical waste storage area?

I was having this conversation today as well.

The key question is “considered adequate by who?”. I remember that EPA did not consider cell phones as adequate communication device in RCRA hazardous waste storage areas about 10 years ago. I don’t know if they have changed their mind in that regard, or if they did, whether the 48 states that have their own hazardous waste regulations followed suit. And there are different kinds of chemical waste storage areas in different states that might impact the answer as well...

So I think that your question needs to be refined a bit to be answerable.

- Ralph

Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org

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