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Date: Jul 19, 2023 15:40 UTC
Author: Kristi Ohr <kohr**At_Symbol_Here**UMASS.EDU>
Date: Jul 19, 2023 15:42 UTC
Author: Snyder, Brenda K <Brenda.Snyder**At_Symbol_Here**UTOLEDO.EDU>
From: pzavon**At_Symbol_Here**ROCHESTER.RR.COM
Subject: Re: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities
Date: Jul 19, 2023 15:42 UTC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: <001001d9ba57$98409270$c8c1b750$@rochester.rr.com>
In-Reply-To: <SJ0PR04MB7773DEB0490049FAC8EE3AE0F739A**At_Symbol_Here**SJ0PR04MB7773.namprd04.prod.outlook.com>
I could speculate that they may have been written by different teams at EPA.
This is an excellent reason to submit comments to all three processes.
Personally, I am bemused, to say the least, that EPA is regulating occupational exposures explicitly, without any apparent reference to or input from OSHA.
Peter Zavon, MS, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Kolodziej, Christopher
Sent: Tuesday, July 18, 2023 9:47 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities
Am I the only one who feels like the EPA is making it up as they go along? Of the three rules they’ve proposed in recent months for chlorinated solvents, none of them are fully consistent with each other (at least in terms of what they’re proposing for use as laboratory chemicals). Nor is it clear what rationale might account for the differences. The proposed exposure limits for perchloroethylene and carbon tetrachloride are 1-2 orders of magnitude lower than that proposed for methylene chloride, yet EPA only proposes requiring exposure monitoring for methylene chloride. At a high level, the approaches towards perchloroethylene and carbon tetrachloride are similar, but the documentation requirements for PPE selection for carbon tetrachloride are significantly more detailed/burdensome/inapplicable in many university labs.
Does anyone have any insight into why these proposed rules aren’t taking a more consistent approach?
Chris
________________________________
Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer
UCLA Environment, Health & Safety | Chemical Safety
Mobile: (203) 241-6515
My working hours may not be your working hours. Please do not feel obligated to reply outside of your normal work schedule.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ralph Stuart
Sent: Monday, July 17, 2023 11:04 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities
Proposal would also ban discontinued uses so they cannot restart |
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