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From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] EXTERNAL: Re: [DCHAS-L] Unfamiliar Material [MOT Exemption Opportunity]
Date: Sat, 18 Feb 2017 06:51:23 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 15a510ff081-3966-e957**At_Symbol_Here**webprd-m106.mail.aol.com
In-Reply-To <00a201d28992$87bf7df0$973e79d0$**At_Symbol_Here**rochester.rr.com>
Peter, I CERTAINLY will keep that in mind if I'm still functioning in 14 months. We are putting together IH experts now for one of the unions for emergency response to safety and environmental problems on location. When we get this up and running, my beady eyes will be looking to set up other experts on retainer for these peripheral regulatory issues.
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: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Feb 17, 2017 10:07 pm
Subject: Re: [DCHAS-L] EXTERNAL: Re: [DCHAS-L] Unfamiliar Material [MOT Exemption Opportunity]
I agree that the MOT exception is a likely candidate - unless they are moving gallons and gallons of material. There is a 200 kg limit per vehicle, and original containers are NOT required, only something equivalent to the original in robustness for transportation.
I'll be retiring in about 14 months. Perhaps after that I could help out on a project to deal with this in some sort of systematic fashion, or at least to develop a system for the industry.
Based on the description provided by Monona, and dependent on the products, packagings and quantities used, it seems like the USDOT "Materials of Trade" exception could be invoked to demonstrate that hazardous materials are being properly transported. Here is the link to a USDOT pamphlet that provides general MOT requirements:
Some notes:
=B7 The MOT exemption typically requires the use of fairly =E2=80=98benign' products that are their original container. The MOT is targeted towards the tradesman who needs to transport several gallons of paint to a work site and use it to paint a building. For example, a worker could go to Home Depot and pick up some flammable varnish and transport it to the house he's working on=E2=80=A6 Thus, the MOT exemption can probably not be utilized for your pyro shipments.
=B7 The MOT exemption is for highway mode only (truck) - Air/Rail/Ship (and international) shipments are not allowed
=B7 The containers should bear the appropriate HazCom information. The use of the =E2=80=98secondary containers' that was described should probably be reviewed to ensure that "-a package of equal or greater strength and integrity" has been used. These containers would also need to be in good condition, closed and display the appropriate HazCom labeling during transport.
=B7 While not tracked to the same extent as other DOT requirements, you would still need to provide appropriate training is in place to demonstrate conformance to DOT MOT transportation and OSHA HazCom requirements.
=B7 While not directly germane, it seems like your industry may also have labor-related union issues. That is, workers who =E2=80=98transport' chemicals as part of a production unit may be doing the work of a different class (i.e., "Drivers") which could lead to grievances, etc. Suggest that these types of conflicts be considered so that mutual cooperation is achieved.
I understand that this topic has veered off from the original discussion - recommend a new =E2=80=98string' be started if others want to comment.
Thanks, Vince.
Vincent P. McKay
Lockheed Martin Aeronautics Company
Environment, Safety & Health - Palmdale 661-572-4329
There are obviously labeling for HazCom issues for what folks carry in there personal vehicles but.......the bigger issue I see is DOT requirements for transport of hazardous chemicals over the open roadways regulated by DOT. We got to the point of NOT allowing researchers to carry hazardous chemicals in personal vehicles. In a chemical company we had lots of researchers, sales, marketing and technical folks who wanted to carry hazardous chems in personal vehicles. There is special DOT requirements for this. We got to the point where we had our chemical delivery trucks carrying all chemicals locally. (Those vehicles were DOT registered and the drivers knew how to handle the paperwork). Anything outside of local delivery was handled by delivery companies that had the delivery equipment and annual training for their employees.
Aaron Chen, MPH, CIH, FAIHA
Sent from Aaron's iPhone.
You sound like you also know what you are doing. Maybe you can refer me to someone who would be able to help scenic artists get their road box liquid paints, dyes, solvents and other chemicals properly labeled for transport. Almost none of these will be in their original containers. They are paints that have been altered and mixed to the colors on a particular set design. These usually are steamer trunk-sized boxes full of all the stuff they will need.
Mostly the crisscross the US from Coast to Coast, but occasionally go across the big and little ponds and some have had these materials confiscated.
And then there are pyrotechnic road boxes, Oy.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
New York, NY 10012 212-777-0062
-----Original Message-----
From: Mark Ellison <Mark**At_Symbol_Here**TANKTRAILERCLEANING.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Feb 17, 2017 10:13 am
Subject: Re: [DCHAS-L] Unfamiliar Material
As a follow-up, the manufacturer called and helped clear up the confusion on our end. Turns out, this material has not been shipped, but the hauler was trying to get pricing in place to quote to the manufacturer for turnkey service, the hauler being my customer. The manufacturer is putting me in touch with the product "steward", so I can determine safe work practices, equipment needs, and disposal options of heels and rinsates.
Thank you to everyone in this list for commenting on and off line. It is a great feeling to know that I have this outstanding resource available to me to help in my life long journey to provide health and safety guidance to my folks.
Mark Ellison
-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of TILAK CHANDRA
Sent: Wednesday, February 15, 2017 1:11 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Unfamiliar Material
Aromatic compound with a trifluoromethyl substitution. From SciFinder.
Tilak
1417782-28-5
Structure:
AS Registry Number 1417782-28-5
C15 H10 Cl F3 O2
Ethanone, 1-[4-(4-chlorophenoxy)-2-(trifluoromethyl)phenyl]-
Molecular Weight
314.69
Boiling Point (Predicted)
Value: 372.5 =B142.0 =B0C | Condition: Press: 760 Torr Density (Predicted)
Value: 1.327 =B10.06 g/cm3 | Condition: Temp: 20 =B0C Press: 760 Torr Other Names
• 1-[4-(4-Chlorophenoxy)-2-(trifluoromethyl)phenyl]ethanone
• 1-[4-(4-Chloro-phenoxy)-2-trifluoromethyl-phenyl]ethanone
Notes
1) chemoselective, Grignard reaction, Reactants: 3, Reagents: 3, Catalysts: 1, Solvents: 3, Steps: 2, Stages: 4, Most stages in any one step: 3 References Process for the preparation of substituted phenoxyphenyl ketones Quick View By Vogelbacher, Uwe Josef et al From PCT Int. Appl., 2015091045, 25 Jun 2015
-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of davivid
Sent: Wednesday, February 15, 2017 12:50 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Unfamiliar Material
A google search on docetaxel pulls up a wikipedia entry having that CAS number, but the structure does not correspond to the name on the SDS.
D
On 15/2/17 9:54 AM, Frankie Wood-Black wrote:
> The CAS No pulls this up in the Sigma Aldrich Catalog - Docetaxel
>
> Does not look like it is on the TSCA Inventory
>
> *Frankie Wood-Black, Ph.D., REM, MBA*
> *Principal - Sophic Pursuits*
> *NOTE - ADDRESS CHANGE - Mailing Address - PO Box 433, Tonkawa, OK
> 74653* *email address fwoodblack90**At_Symbol_Here**gmail.com <fwoodblack**At_Symbol_Here**gmail.com>*
> *or fwblack**At_Symbol_Here**sophicpursuits.com <fwblack**At_Symbol_Here**sophicpursuits.com>*
>
> *580-761-3703*
>
> On Wed, Feb 15, 2017 at 10:37 AM, Mark Ellison
> <Mark**At_Symbol_Here**tanktrailercleaning.com
>> wrote:
>
>> All,
>>
>>
>>
>> I am stymied here. I have a customer who presented a vessel that
>> previously contained a material with the CAS number 1417782-28-5 for
>> cleaning. The chemical name on the SDS is "Ethanone,
>> 1-[4-(4-chlorophenoxy)-2(trifluoromethyl)phenyl]-". I tried to look
>> it up on the CAS site and got "No Results". I called the
>> manufacturer and they couldn't find the product either by CAS number or product number.
>> They said they would get back to me. Any suggestions would be
>> greatly appreciated. I just want to know if I can safely wash this
>> vessel without harming my employees, the environment, or the downstream POTW. Thanks!
>>
>>
>>
>> Mark Ellison
>> --- This e-mail is from DCHAS-L, the e-mail list of the ACS Division
>> of Chemical Health and Safety. For more information about the list,
>> contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
>
> ---
> This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
> For more information about the list, contact the Divisional secretary
> at secretary**At_Symbol_Here**dchas.org
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