Sammye,
Before seeing if the exceptions apply,
would it be wise to evaluate the toxicity of whatever is
included in ??a kit? ?? Maybe, our key(s) need to be
identifying/ensuring:
A. ??no
potential for employee exposure ??
B. What
would/could the consequences be of an unintended employee
exposure to a highly hazardous or toxic compound, since an
accident can happen.
C. What
is your potential liability, if you do not look at the
potential consequences?
I may be getting paranoid, which could
either be based upon the experiences of lessons learned over
many years or simply my age.
But, I have seen multitudes of ??kits ?? with
non-hazardous compounds that would not result in a significant
event if a step in the test procedure went conceivable wrong,
but I have found enough potentials to make me want to take a
keen notice to eliminate or at least control the hazard.
(From the top of my head, think sodium azide, Karen
Wennerstrom with dimethyl mercury, pyrophorics, etc.) Now
where is that list of lessons learned from laboratory
experiments gone wrong? We used to have a list that I
referred to often, long before the CSB started to notice.
Bruce
While I am not sure about the contents of
the kits, some may be exempt under this section of the lab
standard (If you are under the lab
standard)
Sammye
1910.1450(a)(3)
This section shall not apply to:
1910.1450(a)(3)(ii)
Laboratory uses of hazardous chemicals
which provide no potential for employee exposure. Examples of
such conditions might include:
1910.1450(a)(3)(ii)(A)
Procedures using chemically-impregnated
test media such as Dip-and-Read tests where a reagent strip is
dipped into the specimen to be tested and the results are
interpreted by comparing the color reaction to a color chart
supplied by the manufacturer of the test strip; and
1910.1450(a)(3)(ii)(B)
Commercially prepared kits such as those
used in performing pregnancy tests in which all of the
reagents needed to conduct the test are contained in the kit.
On 12/4/2014 3:15 PM, Edward Miller
wrote:
We are currently having a
discussion among our biochemists that their DNA
starter segments, DNA sequencing kits and other
materials like that are not chemicals and therefore
they should not fall under all of the inventory
control and ordering controls we have in place for
things like sulfuric acid or other more readily
recognizable chemicals. Does anyone have any
feedback on how the regulations view these types of
items?
Ed
On Tue, Dec 2, 2014 at 2:18 PM,
Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**keene.edu>
wrote:
I am helping to organize a technical
symposium for next June's ACS Northeast Regional Meeting
in Ithaca, NY on the topic of Green Labs: Balancing
Safety and Sustainability in the 21st Century Chemistry
Lab. this is a similar topic to a symposium DCHAS
sponsored in the San Francisco meeting last fall, which
was quite successful.
The abstracts submission web site will open in January,
but I wanted to start Northeast members of DCHAS
thinking about submitting an abstract for this
symposium. If you are interested in talking about new
environmentally-friendly programs in your chemistry
department or how lab sustainability considerations
impact laboratory safety at your campus, please consider
submitting an abstract. I'd appreciate hearing about
your ideas before the holiday break so that I can send
out reminders when the abstract submission process
begins.
Let me know if you have any questions about this.
- Ralph
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
ralph.stuart**At_Symbol_Here**keene.edu
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