From:
Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Subject:
Re: [DCHAS-L] Fwd: Safe Transportation Recommendations; 2018
Date:
May 20, 2024 21:51 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<19c901daaaff$e9201ff0$bb605fd0$@wcenvironmental.com>
In-Reply-To:
<CAKoY-_yAr07OEiMw6oq-RMwSp13VPEctFu1OJ0h+sd4GYTex_Q**At_Symbol_Here**mail.gmail.com>
It has always been the ACS position (by that I mean CHAS & CCS) that educational outreach is absolutely covered under the MOT. Otherwise it would be really difficult for anyone to do chemistry demonstrations away from their workplace. That exemption has been used for many years.
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
610-322-0657
rphifer**At_Symbol_Here**wcenvironmental.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Mary Ellen A Scott
Sent: Monday, May 20, 2024 10:54 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] Fwd: Safe Transportation Recommendations; 2018
Can you shed some light on my question or direct me to the department that can?
I am contacting you to clarify information on shipping hazardous materials for science fairs.
I have attached an ACS publication and would like to use this process. I agree with the interpretation that these chemicals are part of research or education, which is our business.
I teach shipping and have asked our official training organization about using this application. The feedback was that chemicals for educational purposes would not fall under 173.6 MOT because they are not materials that support a business's operation.
' MOT is used for companies that, during the course of their business, have hazardous material in their vehicle as a principal product that supports the function of their business. Examples include painters, roofers, and lawn care companies.'
Has there been any update to the ACS recommendations for chemicals used in demonstrations or educational activities? This area seems to be open to interpretation.
Thank you for your time and help.
Mary Ellen Scott, Ph.D., CIH, CSP
Case Western Reserve University
EHS - Environmental Health and Safety
Service Building 1st Floor Rm 113
2220 Circle Dr.
Cleveland, OH 44106-7227
216-368-6077
216-368-2236 (Fax)
maryellen.scott**At_Symbol_Here**case.edu
"There is no science without fancy and no art without fact" – Vladimir Nabokov (1899-1977).
--
Mary Ellen Scott, Ph.D., CIH, CSP
Case Western Reserve University
EHS - Environmental Health and Safety
Service Building 1st Floor Rm 113
2220 Circle Dr.
Cleveland, OH 44106-7227
216-368-6077
216-368-2236 (Fax)
maryellen.scott**At_Symbol_Here**case.edu
“There is no science without fancy and no art without fact” – Vladimir Nabokov (1899-1977).
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