Dr. Rogers,
I am offering an alternative theory on WHY the EHS Officer is asking for
pre-approval. Your EHS Officer may be attempting to implement a Control
Banding Policy (multiple sources available, see NIOSH, CCOHS, et.al.)
But, to specifically answer your question, is pre-approval required by a
specific regulation? No. But, the question that needs to be asked by you
and your EHS Officer is what is required to ensure personnel use the proper
hierarchy of controls to limit their respective exposure, based upon the
method of generation, e.g., state of matter, toxicity of the material and
quantity of material being handled. If the purpose is to limit the
appropriate controls to within their respective exposures are these tasks
within his/her purview? Then your EHS Officer is absolutely within their
purview.
Do I think that individual laboratories should be required to have
pre-approval? No. Each lab typically handles ~90% of their chemicals in a
routine exposure pattern that we, as EHS Professionals can/will quantify,
perform JHAs on and limit the exposure potentials. Your EHS Officer may be
attempting to identify those other chemicals, unknowns with no toxicity
testing, potentially designated as potent compounds and requiring more
extensive controls. I would NOT vouch for each department/chemists to know
or even consider the toxicity, determining how the chemicals would be
generated, quantified or adequately determining the controls required. Each
of us have our respective areas of expertise with subsequent roles. The EHS
Officer reviewing each SDS for new chemicals should be considered routine
with their response arising from none, e.g., your examples of sodium
chloride and sodium bicarbonate. What you will receive a response on are
potent compounds, oxidizers, peroxide formers, etc., just to ensure the
quantities used with available controls are within acceptable limits or
recommend additional controls, storage/disposal limitations, etc. Leaving
this to each chemist to determine the hazards, effectiveness of controls,
etc. should be a significant concern. The chemist is looking at the
physical/chemical properties of the compound to be used within a reaction or
an application. The EHS Officer is looking at recognizing the hazard,
control, limitations and disposal of the compound. We are looking at the
same process from different perspectives, a check and balance system that
when used - is effective. It would be easy for your EHS Officer to
pre-approve the existing chemical inventory/uses that have been
evaluated/documented and for you to forward those new SDS requests for new
compounds or a non-routine task. From my experience, chemists typically
rely upon fume hoods to control all exposures, which is wrong! Unless your
chemists keep up to date on the different engineering controls proven to be
effective, required flow rates required considering toxicity, regulation,
etc., to limit exposures - leave that to your EHS Officer. We need to
respect each area of expertise to ensure we are protecting employees and
employers.
BruceV

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of
Neil Edwards
Sent: Friday, August 5, 2016 5:26 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Review of chemicals to be purchased--standard practice?

Janet,

That is absolutely ridiculous. It should be up to the department as to what
chemicals to purchase, as long as they are stored and used properly. I
suggest sending him the SDS and telling him that you need an answer within
two hours because the chemical needs to be ordered today. The SDS that comes
with the chemical should be exactly the same as the one you provided before
ordering, if you are getting it from the vendor website; so I don't
understand why he should be asking for a second copy.
In short, you give someone a little power, and well... you know the rest.

Neil Edwards
Laboratory Manager
Adjunct Associate Professor
Department of Chemistry
LIU Post
Brookville, NY 11548-1300
Email: neil.edwards**At_Symbol_Here**liu.edu

From: "Rogers, Janet" >
Reply-To: DCHAS-L >
Date: Fri, 5 Aug 2016 20:10:56 +0000
To: >
Subject: [DCHAS-L] SDS review of chemicals to be purchased--standard
practice?

To All:

Our EH&S officer has decided that we have to send him the SDS for every
chemical we are going to purchase so that he can review it before we are
allowed to purchase the chemical. Then, he wants us to send him the SDS
that came with the chemical.

Is this a standard practice? I can see reviewing SDS for very hazardous
substances, but even for chemicals sodium chloride and sodium bicarbonate?
I can understand his reviewing the SDS for substances we've never previously
used on campus. However, I think he'll drive himself (and us) crazy if he
looks over every single SDS every time we make a purchase.

I fought to get the administration to allow us to make purchases with a
credit card so we could make purchases shortly before we used chemicals in
class. This procedure let us order smaller quantities and has helped us
reduce our inventory, since we no longer had to "over purchase", just to
guarantee that we would have enough material for our classes should the
purchasing paperwork get held up.

Please let me know what level of EH&S scrutiny of chemical purchases is
considered standard practice at undergraduate academic institutions.

I look forward to your responses.

Janet Rogers, Ph.D.

Professor

Chemistry Department

Edinboro University

230 Scotland Road

Edinboro, PA 16444

phone: 814.732.1539

e-mail: rogers**At_Symbol_Here**edinboro.edu

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