From your lips to the ear of someone who can fix this. And for OSHA to use the General Duty to cite for a chemical for which there is no PEL requires a couple of supine stiffs on the lab floor.
From: Ken Kretchman <kwkretch**At_Symbol_Here**NCSU.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Aug 24, 2017 9:14 am
Subject: Re: [DCHAS-L] Fume Hood Regs
Thanks Harry, I knew someone would get this. OSHA doesn't require any specific ventilation equipment. OSHA requires 1) a chemical exposure risk assessment after which the employer must provide 2) whatever works to keep exposure below any action level or PEL. And since the PPE rules require engineering controls when "feasible" rather than respirators, that leaves the obvious conclusion that ventilation is needed.
From: Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Aug 24, 2017 5:16 am
Subject: Re: [DCHAS-L] Fume Hood Regs
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Smallbrock, Margaret A.
Sent: Wednesday, August 23, 2017 3:35 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Fume Hood Regs
Harry J. Elston, Ph.D., CIH
Principal
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