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From: Bruce Van Scoy <bvanscoy**At_Symbol_Here**TWC.COM>
Subject: Re: [DCHAS-L] Carpet in labs
Date: Jun 26, 2024 22:43 UTC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: <00bc01dac81a$516e77f0$f44b67d0$@twc.com>
In-Reply-To: <1783410248.5776834.1719419045319**At_Symbol_Here**mail.yahoo.com>
Considering that radioisotopes were specified, without the isotopes/activities being used in the lab stated, but they were lead soldering and handling radioactive materials in the same lab, I would evaluate what isotopes have been used, try to find a hot spot with direct measurement (quantify with LSCMS) and analyze or send for analysis for heavy metals with activity levels. Depends upon the isotopes used. They may already have a MW regarding disposal. Obtain a cost estimate for removal (minor) and disposal (major!). If the criteria was not met by your investigation, provide a “what if” alternative if it was. Should be an easy call for anyone who controls the budget – and the liability.
BruceV
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Monona Rossol
Sent: Wednesday, June 26, 2024 12:24 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Carpet in labs
Don't be shy, tell us what you really think, Rob. Monona
On Wednesday, June 26, 2024 at 11:18:52 AM EDT, Info <info**At_Symbol_Here**ilpi.com> wrote:
The Laboratory Standard, 29 CFR 1910.1450 mandates a Chemical Hygiene Plan (CHP), and your CHP, while locally produced, is required under OSHA regs. And your Chemical Hygiene Officer (CHO), is *required* by the Lab Standard to provide the technical guidance to implement that plan, which they are refusing to do. And since you’ve tried nicely, now it’s time to play hardball.
Send these morons an email and cc everyone up your org chart to the presidents’s office, but *especially* the legal/risk management department, and use the exact words “appears to be a willful violation of OSHA regulation 29 CFR 1910.1450” (as well as University policy) and that you recommend all laboratory operations in the space be barred until the situation is rectified. Sometimes you have to be the Safety Nazi, so be it. The words “willful violation” should strike fear into the legal team as they open up the institution to triple penalties when cited, and it also puts in (discoverable) writing a potential liability that, if not acted upon, could be damning.
If you like overkill, get the local fire marshal involved. Invite them to come do an inspection and then poke them to think about the potential fire hazard of a highly flammable substance with a foam rubber backing (which produces thick toxic smoke when burned) covering the floor where a flammable material fire is already a significant hazard and risk.
Best wishes,
Rob Toreki
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