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Previous by Date: Subject: Re: [DCHAS-L] Lab Standard vs HazCom Date: Saturday, January 8, 2022 at 7:38:36 AM Author: Richard Palluzi <000006c59248530b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> |
Next by Date: Subject: Re: [DCHAS-L] Lab Standard vs HazCom Date: Sat, 8 Jan 2022 16:39:19 -0500 Author: James Kaufman |
> >I think this discussion misses the point a bit. I have seen numerous research laboratories that use drums to feed or collect products from hoods. Not terribly common certainly but not that uncommon. I do not think the size of the container(s) have any relevance to is it or is it not a laboratory.
>
I agree that the nature of 'laboratory' is difficult to pin down and the regulation reflects that.
The concrete example I can think of this along these lines is a metal parts cleaning facility I visited associated with a synchrotron. The whole enterprise was called a 'lab', although hundreds of scientists and technicians worked there and very few thought of themselves as chemists. The metal parts cleaning group (who had been doing this work for 20 years) use 100 gallon vats of primarily nitric acid to clean the instruments and pieces of the synchrotron because the objects in the beam have to be very pure to achieve the experimental aims. When I walked into the room where the parts cleaning took place, I said to myself 'this ain't no lab'.
However, when I talked to the two people who did the parts washing full time, they knew more about nitric acid and its hazards than anyone else I had talked to. They could tell by the viscosity and color of the bath when it was time to change the acid. They inspected each piece before it went in the bath for any impurities that might react and screw up the whole bath. They had dealt with spills of many kinds. And they were very conscious about passing their knowledge along to new workers, both to protect the process and as a point of pride. I don't think going over SDS's for their chemicals would add a lot of value to their safety. In this case, an appropriately written Chemical Hygiene Plan that supported the SOPs they had in place would be a better approach to managing the chemical hazards involved.
I guess my point is, that if you are really torn between the lab standard and hazcomm, talk to the staff involved and let them tell you what they need in terms of safety support; the EHS role is to frame that support in terms of the regulatory options. I think that both the lab standard and hazcomm are performance-oriented enough to support a practical approach on this question. Now, when it comes to RCRA and other EPA regulations, that's another story...
- Ralph
Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org
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