From: Melody Russo <melody.russo**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] Citation for storage separation of acids and bases
Date: Sat, 23 Jul 2016 18:09:57 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAA0VgioxM0JMu5Ju7UfkvyB_dZFpAWbsNtTQENE-1eyLyn_vSA**At_Symbol_Here**mail.gmail.com
In-Reply-To <15618041b9c-7c22-6185**At_Symbol_Here**webprd-a50.mail.aol.com>


Thanks for your feedback Monona,
We are dealing with tanks, not cans or pails. So, I'm looking more for directives about tanks of acid and base in same secondary containment, or situations of that nature.

I do appreciate your feedback for our maintenance areas, however.
Thanks again,
Melody

On Sat, Jul 23, 2016 at 9:48 AM, Monona Rossol <0000012821515289-dmarc-request**At_Symbol_Here**listserv.med.cornell.edu> wrote:
I always wince when I hear your question. It usually means some employer has said "show me an OSHA regulation that says I have to do that and I'll do it." OSHA is the "minimum" in safety and a weak fish when it comes to standing on it's hind legs that you follow OSHA at your peril.

I suggest you go to OSHA's web site and search for "storage of reactive chemicals" About 4th or 5th down will be a letter of interpretation from 2001 in which OSHA says that that flammables and corrosives can be stored in the same cabinet if the manufacture's rules for storage on the MSDS for the chemicals says it is OK and the containers are of the right type, etc. Well, not good practice. And it would mean checking each corrosive's data to see if there are any solvents in the cabinet with which it can react.

And will following this corrosive by corrosive policy protect your liability should there be a problem? Not likely. The lawyers will probably bring NFPA and other storage standards to court and ask why you didn't follow accepted practice.

It is such a little thing to just purchase corrosive and flammable cabinets and teach people to use them properly -- problem solved. That is the only option my reports recommend, ever.


Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062



-----Original Message-----
From: Melody Russo <melody.russo**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Sat, Jul 23, 2016 3:12 am
Subject: [DCHAS-L] Citation for storage separation of acids and bases

Can anyone give me a regulatory citation or safety association/ research institute code for storing acids and bases separately? I know it is a good practice, but want a reference from a recognized entity.

Thanks!

Melody Russo
Environmental Compliance Manager

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