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Date: Tue, 18 Jan 2011 07:15:39 -0600
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Beth Shepard <Beth.Shepard**At_Symbol_Here**SIAL.COM>
Subject: Re: access to chemical stockroom
In-Reply-To: <AANLkTimSLYL1gCC7qF2-4zO4hF+EFfY9NZ=m3gS0F+ej**At_Symbol_Here**mail.gmail.com>
Good morning--
Aside from the hazard issues, there may also be a regulatory problem with
open access to certain chemicals (ex. DEA List I & II chemicals). You'd
need to check the federal/state/local regulations (DEA, Dept. of Homeland
Security, TTB, etc.) on what security they require, what reports need to
be filed, etc. My knowledge of these regs. is based upon the seller's
responsibilities, not the end-users responsibilities.
With open access, you're relying on the faculty to accurately complete the
log, (with the potential for excuses such as ...I'm in a hurry, I'll come
back & fill in the log later; I think the log's another wasted exercise,
why should I waste my time; ...)If the access is limited to dedicated
stockroom personnel, filling out that log & keeping the inventory balanced
would be/should be part of their job.
In my personal opinion, at a minimum, removing chemicals from a storeroom
should involve as much documentation as removing a book from the library.
Beth
Beth Shepard / Technical Compliance Specialist
Regulatory Compliance
6000 N. Teutonia Ave. / Milwaukee, WI 53209 / USA
P: (414) 438-3850, x5471
sigma-aldrich.com
Patrick A Ceas
Sent by: DCHAS-L Discussion List
01/17/2011 09:10 PM
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[DCHAS-L] access to chemical stockroom
Hi all,
I know that this or a similar question has been asked before, but please
allow me to ask it once again in a simplified form: For your central
chemical storeroom, how is access to chemicals controlled? (assume that
the person who is picking up the chemical is wearing appropriate PPE &
uses an appropriate transport container):
(a) Open Access: all faculty are allowed to enter and take what they want
as long as they log the user & amount.
(b) Closed Access: no faculty are allowed to enter, and only a few
individuals (e.g., trained stockroom employees) have access to the
chemicals; faculty request a chemical, and that chemical(s) is either
delivered or can be picked up from a check-out window.
(c) Limited Access: all faculty have "Open Access" to a subset of
chemicals with "lower" hazard ratings and they can simply log out the
amount taken; however, for chemicals with "higher" hazard ratings (e.g.,
NFPA of 3 or 4) it is "Closed Access."
Thanks. Feel free to reply directly to me or to the list.
Pat
--
Dr. Patrick Ceas
312 Regents Hall of Natural Sciences
St. Olaf College
Northfield, MN 55057
507-786-3560
This message and any files transmitted with it are the property of
Sigma-Aldrich Corporation, are confidential, and are intended
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text/html;
Good morning--
Aside from the hazard issues, there
may also be a regulatory problem with open access to certain chemicals
(ex. DEA List I & II chemicals). You'd need to check the federal/state/local
regulations (DEA, Dept. of Homeland Security, TTB, etc.) on what security
they require, what reports need to be filed, etc. My knowledge of these
regs. is based upon the seller's responsibilities, not the end-users responsibilities.
With open access, you're relying on
the faculty to accurately complete the log, (with the potential for excuses
such as ...I'm in a hurry, I'll come back & fill in the log later;
I think the log's another wasted exercise, why should I waste my time;
...)If the access is limited to dedicated stockroom personnel, filling
out that log & keeping the inventory balanced would be/should be part
of their job.
In my personal opinion, at a minimum,
removing chemicals from a storeroom should involve as much documentation
as removing a book from the library.
Beth
Beth Shepard /
Technical Compliance Specialist
Regulatory Compliance
6000 N. Teutonia Ave. /
Milwaukee, WI 53209 /
USA
P: (414) 438-3850, x5471
sigma-aldrich.com
Patrick A Ceas <ceas**At_Symbol_Here**STOLAF.EDU>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
01/17/2011 09:10 PM
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Hi all,
I know that this or a similar question has been asked
before, but please allow me to ask it once again in a simplified form:
For your central chemical storeroom, how is access to chemicals controlled?
(assume that the person who is picking up the chemical is wearing
appropriate PPE & uses an appropriate transport container):
(a) Open Access: all faculty are allowed to enter and
take what they want as long as they log the user & amount.
(b) Closed Access: no faculty are allowed to enter, and
only a few individuals (e.g., trained stockroom employees) have access
to the chemicals; faculty request a chemical, and that chemical(s) is either
delivered or can be picked up from a check-out window.
(c) Limited Access: all faculty have "Open Access"
to a subset of chemicals with "lower" hazard ratings and they
can simply log out the amount taken; however, for chemicals with "higher"
hazard ratings (e.g., NFPA of 3 or 4) it is "Closed Access."
Thanks. Feel free to reply directly to me or to
the list.
Pat
--
Dr. Patrick Ceas
312 Regents Hall of Natural Sciences
St. Olaf College
Northfield, MN 55057
507-786-3560
This message and any files transmitted with it are the property of
Sigma-Aldrich Corporation, are confidential, and are intended
solely for the use of the person or entity to whom this e-mail is
addressed. If you are not one of the named recipient(s) or
otherwise have reason to believe that you have received this
message in error, please contact the sender and delete this message
immediately from your computer. Any other use, retention,
dissemination, forwarding, printing, or copying of this e-mail is
strictly prohibited.
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