Safety Emporium eyewashes
Safety Emporium eyewashes

Interactive Learning Paradigms, Incorporated

DCHAS-L Discussion List Archive

About This Archive  |   DCHAS-L 2022 Index   |   DCHAS-L Yearly Index   |   DCHAS-L Home Page

About This Archive

DCHAS-L 2022 Index

DCHAS-L Yearly Index

DCHAS-L Home Page


Previous by Date

Subject: Re: [DCHAS-L] Chemical storage guidance for bases

Date: Oct 19, 2022 20:16 UTC

Author: Reinhardt, Peter <peter.reinhardt**At_Symbol_Here**YALE.EDU>

Next by Date

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

Date: Oct 19, 2022 21:05 UTC

Author: pzavon**At_Symbol_Here**ROCHESTER.RR.COM

From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>

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

Date: Oct 19, 2022 20:44 UTC

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

Message-ID: <CAEwQnqjmPHiAHMx1oUGBbu7_G3juK6EyT4Nm0OtoNdo7bMkQAg**At_Symbol_Here**mail.gmail.com>

In-Reply-To: <415E84F6-786F-4CAD-B3F5-408DAEE06BE3**At_Symbol_Here**rstuartcih.org>

Demystify: 
Ralph,

It would appear, at least for a Small Quantity Generator, that a cell phone alone does not meet the requirement.  (see text below)

Note that when I quickly scanned the guidance document for (Michigan's) Very Small Quantity Generators there is no mention of telephones being required.

Some general thoughts:

- Not everyone, even in this day and age, carries a cellphone
- Some labs, especially with proprietary research, animal research, and other sensitive research may prohibit cell phones
- Cell phones may not work in some buildings and some areas of the country may have different area coverage by different phone carriers.

You might consider centralized "emergency" phones in the hallway that (only) ring 911.


From the Federal Register:

https://www.federalregister.gov/documents/2016/11/28/2016-27429/hazardous-waste-generator-improvements-rule

b. The meaning of “immediate access.” Preparedness and prevention provisions include the condition that, whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee, unless such a device is not required. At issue is whether the phrase “immediate access” is clearly understood or whether additional clarity is necessary. EPA proposed to modify this language to include the parenthetical “(e.g., direct or unimpeded access)” after the phrase “immediate access.” EPA requested comment on the usefulness of modifying this language.

The majority of commenters supported this modification, although one commenter expressed concern regarding what would constitute immediate or unimpeded access. Another commenter requested clarification as to whether access to a cell phone satisfies the requirement for immediate access to an alarm or communication device. [Bold my emphasis] EPA believes that, although cell phones are a useful means of communication, they should not be relied upon solely to satisfy this requirement. The Agency is therefore finalizing § 262.16(b)(8)(iv) and § 262.254 as proposed.

Also see:
 § 262.16(b)(8)(iv)
Access to communications or alarm system.

(A) Whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access (e.g., direct or unimpeded access) to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee, unless such a device is not required under paragraph (a)(8)(ii) of this section.

(B) In the event there is just one employee on the premises while the facility is operating, the employee must have immediate access (e.g., direct or unimpeded access) to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance, unless such a device is not required under paragraph (a)(8)(ii) of this section.

On Wed, Oct 19, 2022 at 2:14 PM Ralph Stuart <ralph**At_Symbol_Here**rstuartcih.org> wrote:
> >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

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter @acsdchas


--
Jeff Lewin
Director of Chemical Laboratory Operations
Research Integrity Office
Laboratory Operations
205 Lakeshore Center 
Michigan Technological University

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter @acsdchas

Previous post  |  Top of Page  |  Next post