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Subject: [DCHAS-L] FAA Safety on Emergency Preparedness
Date: Monday, September 9, 2019 at 8:48:14 AM
Author: DCHAS Membership Chair <membership**At_Symbol_Here**DCHAS.ORG> 		Next by Date:
Subject: Re: [DCHAS-L] CHO at museum asks for our help
Date: Mon, 9 Sep 2019 14:07:26 +0000
Author: Michael

From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] CHO at museum asks for our help
Date: Mon, 9 Sep 2019 09:16:34 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: CAEwQnqhtPqcLobp3fH3Qy46iwFcSTxoEYsO0y4sFwixxcDCR_g**At_Symbol_Here**mail.gmail.com
In-Reply-To <113BF5FD-479C-43D7-9B5C-B5E449B1B6AF**At_Symbol_Here**dchas.org>


In addition to the Materials of Trade Exemptions, if the museum workers are (local) Government employees (not contract employees) they may be eligible for exemptions from certain US DOT regulations on transporting hazardous materials. Many State Universities take advantage of this for moving hazardous waste and other chemicals.

https://danielstraining.com/the-government-employee-exemption-to-the-usdot-hazmat-regulations/

They may want to run this by their legal counsel. In addition, they should also check with their insurance carrier to make sure they are covered in the event of a chemical release during an accident or if they need additional coverage.

They also need to review their hazard communication rules and other pertinent rules on working with chemicals. In Michigan, for example, working with an eye corrosive, such as acetic acid, requires access to an eyewash.

And, finally, they would need to meet any hazardous waste management rules (labeling, collection, etc.) required by California/EPA.

Jeff


On Sun, Sep 8, 2019 at 6:28 PM DCHAS Membership Chair <membership**At_Symbol_Here**dchas.org> wrote:
From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Re: CHO at museum asks for our help

A really nice CHO at an LA museum found that the conservation staff has plans to transport chemicals from the museum to offsite facilities where they would perform treatment on objects. The kits would vary depending on the treatment needed, but most of the time the kits would contain acetone, isopropanol, toluene, xylene, acetic acid, mineral spirits. The CHO is not familiar with the DOT and other regulations for transporting/labeling chemicals. But he ran across Title 49 Part 173.4 Small quantities for highway and rail outlines and realized he could have some issues with this plan.

This is not an area I'm strong in and usually suggest a consultant. If any of you have this area nailed and could help, or if you know of a reasonable consultant to refer this to, the CHO can be reached at:

Carlos Aponte
Chemical Hygiene Officer
Los Angeles County Museum of Art
Conservation Center
5905 Wilshire Blvd.
Los Angeles, CA 90036

(323) 932-5899
CAPONTE**At_Symbol_Here**LACMA.ORG

Thanks to all, Monona

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--
Jeff Lewin
Chemical Safety Officer
Research Integrity Office
Laboratory Operations
207 Advanced Technology Development Complex (ATDC)
Michigan Technological University

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