From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Grassroots lab safety examples?
Date: Wed, 11 Oct 2017 11:37:19 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 15f0c153c01-c08-1b84**At_Symbol_Here**webjas-vac170.srv.aolmail.net
In-Reply-To


A few last points and then I'll stiffle.  You can't train about GHS or SDSs without teaching the politics.  Just to show you why you absolutely need to include politics, try to think of any other rational way to explain to your trainees why the PELs are generally less protective than the TLVs or the German MAKs?  Certainly the toxicity of the chemical doesn't change because the workers are under a different standard!  So the decisions about toxicity and exposure limits are NOT left to the toxicologists.  The decisions are left to the people who PAY the toxicologists.


Show the the trainees the rules OSHA has to meet when setting a PEL.  You will see the language clearly shows OSHA cannot set a PEL, no matter how obvious it is where it SHOULD be set, at a level that will financially harm the industry.  In other words, the health of the industry, under our laws, trumps the health of the workers.  

And when a chemical is known to have no safe level of exposure, the MAK sets no limit and, instead, requires employers to use the best protection available (cost be damned) to keep the exposure as close to zero as possible. Then compare this to the prerule discussions over such chemicals in the U.S. Federal Register which boil down to OSHA arguing with industry experts on just how many workers it is OK to kill.

At this point, you need a very short module on your trainee's "rights" under worker's comp which will complete this picture. 

Workers need to know that, under our laws, they are potentially a disposable commodity. They can only fight to protect themselves in the workplace when they fully understand the weapons and the battlefield.  As trainers, we owe them that knowledge. 

Now, they are ready to look at the data in GHS SDS Section 11.


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: David C. Finster <dfinster**At_Symbol_Here**WITTENBERG.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Wed, Oct 11, 2017 10:01 am
Subject: Re: [DCHAS-L] Grassroots lab safety examples?

.... > >Please remember, I am not a toxicologist, and only toxicologist can interpret toxicological data. (Tilak)

Is this true? I often see toxicological data on Safety Data Sheets, which have a much broader audience than toxicologists. (Ralph) ...

This raises a vexing question, and one that I discuss with my students when introducing the variety of toxicological data that are present in SDSs and elsewhere: What do you DO with this information? An LD50? A PEL? We can come up with general guidelines about "lower values" being more hazardous than "higher values", but students (and chemists) need to make decisions about lab behaviors in practical and prudent fashions. "Should I work with this chemical only in a hood? Should I wear gloves? If ingestion seems nearly impossible in most lab situations, of what value is an LD50?" Of course, the best answer is to be prudent: Wear appropriate PPE, handle chemicals prudently, and use a hood except in situations where the risk is negligibly low. But now we have moved from hazard identification to risk assessment. And, sadly, MSDSs and SDSs are notoriously "overly precautious" and often contain statements that, to "reasonable practitioners", seem ridiculous. The !
GHS at least gives a first-order clue of the hazard level with either "warning" or "danger."

And, of course Monona would remind us: How do we assess the hazard and risk of chemicals for which there is no toxicological data? What do we assume? How do we behave in the absence of hazard information?

So, Tilak may be correct that only a toxicologist can (authoritatively) interpret toxicological data, but Ralph points out that the rest of us who are in the lab must decide how to interpret these data. I do see the GHS as a useful system for the bench chemist - but the vast numbers of scientists who use chemicals but don't think of themselves as chemists. All teachers who teach general chemistry (where these issues must be discussed...) know that the vast majority of our students are biology majors - some of whom will someday work with chemicals on a daily basis and may or may not develop the kind of safety awareness that we seek to provide in undergraduate and graduate chemistry programs.

The educational challenges here are considerable in scope and depth.

Dave

David C. Finster
Professor, Department of Chemistry
University Chemical Hygiene Officer
Wittenberg University
937-327-6441
http://userpages.wittenberg.edu/dfinster/index.html



-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Stuart, Ralph
Sent: Wednesday, October 11, 2017 7:50 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Grassroots lab safety examples?

>Replacement of hexanes with pentane. The neurological effects of
>n-hexanes are well known since 1960 through occupational studies

Good example. Another example of this discovery was related to auto mechanics in California.
http://www.elcosh.org/document/3543/d000830/California%2BHazard%2BAlert%2B-%2Bn-Hexane%2Buse%2Bin%2BVehicle%2BRepair.html?show_text=1

> >Please remember, I am not a toxicologist, and only toxicologist can interpret toxicological data.

Is this true? I often see toxicological data on Safety Data Sheets, which have a much broader audience than toxicologists.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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