I'm really curious to know if the EPA and OSHA are using a shared definition of "laboratory use". If they are, then a determination that laboratory use poses an unreasonable risk to human health should be impossible. Per the Lab Standard, laboratory use only exists where the practices and equipment used are effective at protecting users from exposure.

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Harry Elston
Sent: Friday, July 8, 2022 5:44 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Chemical Safety headlines (12 articles)

Dan,

This is just one of the reasons why EPA needs to get out of the occupational safety business. Perhaps with the latest SCOTUS decision reigning in EPA's overreach, ACC and individual manufacturers will begin the processes to stop their intrusion on occupational safety under SNUR/PMN regulations.

Harry

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Daniel Kuespert
Sent: Friday, July 8, 2022 05:43
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Chemical Safety headlines (12 articles)

On Jul 8, 2022, at 06:03, Ralph Stuart <membership**At_Symbol_Here**DCHAS.ORG> wrote:

US EPA FINDS NEW RISKS FOR 3 SOLVENTS: METHYLENE CHLORIDE, N-METHYLPYRROLIDONE (NMP), AND PERCHLOROETHYLENE
...
The changes include no longer assuming workers wear personal protective equipment. For each of the three solvents, eliminating that assumption resulted in a slight increase in the number of uses with unreasonable risks. …

While I certainly follow the justification for assuming workers don't wear PPE, since many times they don't, and PPE is supposed to be a last-ditch protection, I do wonder how many uses of chemicals in the lab would be judged "unreasonable risks," given that there is little to protect many researchers from the chemicals they're working with other than the fume hood (if they use it correctly) and their gloves/lab coat.

Because it's so hard to find a good glove for NMP, I try to discourage its use whenever I can. I probably should do so for CH2Cl2, as I recall (without looking at a compatibility chart) that it goes through nitrile gloves, particularly exam gloves, pretty quickly.

Is it even possible to reduce that risk in the lab, practically speaking? Granted, researchers are using less dichloromethane or whatever than someone removing graffiti from an overpass, so the supply-side of the risk is reduced, but I don't really see an inherent way to reduce the risk due to use conditions in a lab without going to exotic solutions like remote manipulators (waldos).

Regards,

Dan

-------------------------------------------------

Daniel Kuespert, PhD, CSP

Member, American Chemical Society (ACS)

Member, ACS Division of Chemical Health & Safety (CHAS)

Chair-elect, CHAS 2022

Associate, CCS, 2021-2022

CHAS Fellow

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