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Previous by Date: Subject: Re: [DCHAS-L] Interpreting NFPA 45 Section 12.3.2.1.2 Date: Wednesday, April 10, 2019 at 6:16:44 PM Author: Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM> |
Next by Date: Subject: Re: [DCHAS-L] Interpreting NFPA 45 Section 12.3.2.1.2 Date: Wed, 10 Apr 2019 22:33:04 +0000 Author: Monona Rossol |
Thank you Rob. That is wonderful. I am no longer confused about the appearance of the two words in different documents. Very helpful. Monona
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From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Wed, Apr 10, 2019 4:55 pm
Subject: Re: [DCHAS-L] Interpreting NFPA 45 Section 12.3.2.1.2
At the FAA, of all places, "What's the only word that means mandatory? Here's what law and policy say about "shall, will, may and must.":
https://www.faa.gov/about/initiatives/plain_language/articles/mandatory/
And also https://plainlanguage.gov/guidelines/conversational/shall-and-must/
You can read about the evolving opinion of whether "shall" = "must" (short answer: no) at those sites.
My suggestion to you is that you tell your clients that it clearly says "shall" and doesn't say "may" or "optionally". Which gives you the imprimatur that you're talking about even if ooodles of legal experts can't figure it out themselves! The restated version of that is, of course. W.C. Field's famous quote "If you can't dazzle them with brilliance, baffle them with b*******"
Rob Toreki
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On Apr 10, 2019, at 4:12 PM, Margaret Rakas <mrakas**At_Symbol_Here**SMITH.EDU> wrote:
Folks--I would appreciate your help with making sure I interpret this section of NFPA 45 (2019) correctly-
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12.3.2.1.2-"Experiments or demonstrations that involve or produce hazardous quantities of fumes, vapors, particulates or gases SHALL (my emphasis) be performed in a chemical fume hood or other ventilation device, including demonstration hoods or other devices that meet the requirements of 2.1.1 of ANSI/AIHA Z9.5..that is, able to capture the materials being evolved."
In the next section (12.3.2.1.3), experiments performed outside of a fume hood are discussed in terms of using a protective shield or keeping viewers at least 10 feet away.
My reading is that because SHALL is used in 12..3.2.1.2, ALL experiments involving hazardous quantities of fumes, etc. MUST occur in a fume hood or other containment device. (Section 12.3.2.1..3 is referring to demonstrations that DON'T involve hazardous quantities of fumes, etc).
1) Am I correct in my reading?
2) Would moving a 6 ft Rubens Tube, which requires flammable gas in order to produce the demonstration, to an outdoor setting with viewers 10 feet away meet the spirit of 12.3.2.1.2? Or would NFPA 160 come into play? [If you haven't heard of this, google "Rubens tube" or "flame tube"-- there's some interesting Youtube videos]
As much I enjoy Youtube for catching up on stupid cat videos, SNL skits and the like, I really hate it at work....
Many thanks for your thoughts-don't know what I'd do without this group--totally worth my ACS dues several times over!
Margaret
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Margaret A. Rakas, Ph.D.
Manager, Inventory & Regulatory Affairs
Clark Science Center
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