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From: Clark, Eric J <CLARKEJ**At_Symbol_Here**LATTC.EDU>
Subject: Re: [DCHAS-L] Cleaning Lab coats
Date: Dec 13, 2024 18:52 UTC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: <BY5PR03MB5266D682DDC4C09A9C50AF56B6382**At_Symbol_Here**BY5PR03MB5266.namprd03.prod.outlook.com>
In-Reply-To: <CAEiU9vBo3iNicgFv-5ufd9SgB4KHLWzXSpmNnmtkDXFgXqEgMg**At_Symbol_Here**mail.gmail.com>
Keep in mind that these rules were designed for industrial settings – not necessarily academic settings – but then also keep in mind that your students are eventually going to work in industry, so it’s better to get used to it now. Or
use the de minimis exemption for ppe, 40 CFR 261.3(a)(2)(iv)(D), not sure if that applies to taking ppe home. Maybe more on that in another enlightening DCHAS communique.
If your labs are all kid-friendly and don’t involve anything that would produce RCRA hazardous waste (e.g., only m&m food coloring, NaCl) then students can take their own lab coats home and just wash them – like we all did in general chemistry
lab, with chromium chloride and silver nitrate splatters, and beads of broken thermometer mercury in all of the lab drawers, where we kept our lab coats.
However, if you do an actual hazardous waste determination (e.g., D004 Arsenic, D005 Barium, D006 Cadmium, D007 Chromium, D008, Lead, D009, Mercury, D010 Selenium, D011 Silver) and find that there’s a risk that students will take this material
home, then you’ll have to do an actual risk management determination. And there are also a lot of justice warriors out there now looking for something, anything, to say to shut down a program.
There’s also a gray area that many academic institutions try to exploit, and that’s saying that students aren’t employees (as the O in OSHA means, Occupational) so they argue that OSHA standards don’t necessarily apply. However, the California
Dept of Ed stymied that discussion by saying that if your programs aren’t up to State regulatory standards (Safety, Health, Fire, anything), regardless employment status, then your program risks losing accreditation, like what almost happened with the cosmetology
program here when the barbering inspector stopped by.
Eric
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Jonathan Dannatt
Sent: Thursday, December 12, 2024 1:25 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Cleaning Lab coats
I was also always curious about this. In terms of a University setting, is it the University's responsibility to provide a cleaning service for lab coats? In other words, if lab coats are required in an undergraduate lab, do the students
take the lab coats home at the end of the semester?
Any feedback on what you all do in your institutions would be really helpful.
Thank you,
Jonathan
On Thu, Dec 12, 2024 at 1:05 PM Clark, Eric J <CLARKEJ**At_Symbol_Here**lattc.edu> wrote: