From my understanding:

1. Anytime you are dealing with caustics OSHA requires an eyewash station and a safety shower would be recommend with batteries containing acid since they could splash over a large area if one is dropped or explodes when being recharged . (CFR1910.151(c)) also Current directive number STD 01-08-002.
2. As long as the original label is intact and the product is in the original container, then no additional labeling should be required. If you are not using them according to: OSHA does not require that MSDSs (SDS) be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. This exemption in OSHA's regulation is based, however, not upon the chemical manufacturer's intended use of his product, but upon how it actually is used in the workplace. Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the properties of those hazardous chemicals. Then they will require an SDS.
3. There are several groups that will offer training, one is the Lab Safety Institute, that will prepare you for the NRCC Certified Chemical Hygiene Officer test. The division also offers lab safety training at most if not all ACS larger meetings, other will have more info. on this.

It is also good to look at the standards interpretations in OSHA for additional information on the regulations.

Your hazardous communication program could mean you apply GHS/HMIS information to all chemicals so you will need to check there. What OSHA requires is not always what is written in organizational programs and you must follow your organizations program since it can be more restrictive than what OSHA requires. I have seen some programs written that require GHS labels and SDSs on all chemicals used in the laboratory.

Am sure you will hear from many others.

Jeff

Sent from Mail for Windows 10

Hello,

I am new the the chemical hygiene officer job at a small college in TN. I recently rewrote our chemical hygiene plan, which was very outdated. Under our chemical hygiene plan, I am in charge of the waste and safety for engineering, nursing, chemistry, biology, our gross anatomy lab, art, physics, and physical plant. I think I'm starting to figure some things out, but I have some questions I was hoping you all could help with.

1) Our engineering department has a large number of lead-acid batteries. I am under the impression that they need to have an eyewash and a shower available for the labs in which they use these, as well as proper GHS/HMIS labels on the batteries themselves. Is this true or am I way off base?

2) Engineering also has a large number of wood glue, cutting oil, and WD-40 containers. Refrigerants and coolants are also out on the benches in these labs. Do these need GHS/HMIS labels or are they okay as is?

3) I know there's no formal CHO training, though I have taken the Lab Safety Institute's course. What other training would you suggest or know are required for handling hazardous waste, biohazard waste, and other CHO responsibilities at academic institutions? (If this is a dumb question, please give me some grace - I'm new at this!)

Thanks,

Kristen

Kristen Mudrack, PhD

Assistant Professor of Chemistry

kemudrack**At_Symbol_Here**milligan.edu

Office: (423) 461-8907

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