Good catch. There might be a lab or R&D exclusion in the transportation, like DOT with CFR49. They may want to know volume, and who will be handling.
On Sun, Sep 8, 2019 at 7:19 PM Harry J. Elston <harry**At_Symbol_Here**midwestchemsafety.com> wrote:
Monona - See if they qualify under the "Materials of Trade" exemptions in 49CFR173.6.
The ACS Committee on Chemical Safety had a whitepaper on it but evidently they have been scrubbed from the website. I will send it to you off-list. If it's useful, pass it on.
Harry
On Sun, Sep 8, 2019 at 5:28 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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--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas++++++Harry J. Elston, Ph.D., CIHPrincipal, Midwest Chemical Safety, LLC
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