Dear CHAS, The Building Code rules here with the Fire Marshal and
building inspectors.  Those folks do not enforce any OSHA or EPA regs.

Janet Baum, AIA, Principal
Health, Education + Research Associates, Inc.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Gordon Miller
Sent: Monday, May 21, 2007 10:03 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] NFPA standards

Unfortunately, safety can be summarized by paraphrasing Mao ze Dong. 
He said "Justice grows from the barrel of a gun." Figuratively, 
safety grows from the barrel of a gun. The gun is enforcement. Fire 
Marshals can enforce NFPA45, etc. and they have significant 
enforcement authority.

NFPA IS regulatory with more certain enforcement, via fire 
inspections, than OSHA or EPA.


>
>
>Recently our Fire Marshall began a series of Lab Inspections,
>concentrating primarily on quantities of chemicals. This required all
>the researchers to provide an inventory for the labs,  which was not a
>problem, since one is required as part of the University's Chemical
>Hygiene Plan.
>
>
>
>My question to the List is :     OSHA's Lab standard is
>performance-based, and Law;  EPA's RCRA regulations, while
prescriptive,
>have become institutionalized    because no one wants a Consent Order
>(speaking from experience).    NFPA 45 is not Law, yet seems to trump
>OSHA & RCRA, because Building Codes make it appear regulatory.
>
>
>
>Even if a researcher manages his/her chemical inventory properly
>(labeling, segregating), and their hazardous wastes properly (labeling,
>segregating), it appears that the NFPA holds them to higher standards.
>Researchers are questioning this.   And even if they comply by removing
>some chemicals ,     they say they will just order more after the Fire
>Marshall inspection is completed.
>
>
>
>Are any EH &S professionals finding this a problem?
>
>
>
>
>
>________________________________
>
>
>
>________________________________
>
>Stefan Wawzyniecki, CIH, CHMM      NRCC-CHO      University of
>Connecticut  Chemical Health & Safety
>
>________________________________
>
>
>
>

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