We had a peer review audit back in March, and the violation information that was given to us was a bit sketchy, at least to my mind.
We are a university, and as such we carry out research that sometimes results in the development of a new compound. This compound must then be characterized, sometimes in house and sometimes at other facilities. The amounts sent off are small quantities, and the current question seems to be whether or not we come under 40 CFR 720.36 (b)(1) or 40 CFR 720.36 (b)(2).
In other words, do we need to characterize the risks of these new compounds, or will we be in compliance by having a warning accompany the compound, something along the lines of: "Experimental Material: This material is not listed on the Toxic Substances Control Act inventory. It should be used for research and development purposes only under the direct supervision of a technically qualified individual."
Laboratory Coordinator & Safety Officer / Part-time Lecturer
Baylor Univ. Dept. of Chemistry and Biochemistry
Office: BSB E.111
Phone: (254) 710-2002
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