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Subject: Question about regulations
Date: Thu, 10 Jun 2010 16:14:03 -0500
Author: "Humphrey, Karalyn J." 		Next by Date:
Subject: Re: Question about regulations
Date: Thu, 10 Jun 2010 16:39:04 -0700
Author: "Russell Vernon, Ph.D."


Date: Thu, 10 Jun 2010 18:42:26 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Georjean Adams <gla**At_Symbol_Here**EHSSTRATEGIES.COM>
Subject: Re: Question about regulations
In-Reply-To: <CE82A091FC41F7488B2C2E8F0FFF6BC804116EF189**At_Symbol_Here**FS2.baylor.edu>

I assume this was under TSCA.
Does Baylor have commercial chemical activity?  Are you working on 
chemicals that you hope may eventually be commercialized?  If so, 
there is a minimum amount of review and documentation required to 
qualify for the R&D exemption for new chemical substances 
premanufacture notification.  See EPA's site: 
http://www.epa.gov/opptintr/newchems/pubs/randdexemp.htm

Requirements depend on who's doing what where.

Georjean Adams


>Hello,
>
>My name is Karen Humphrey and I'm the safety officer for Baylor's 
>Chemistry Department.  I'm trying to sort out the violations we 
>received from an EPA audit that was done recently.  One of the 
>violations that we received was for not having the proper 
>documentation for new chemicals made by our research groups involved 
>with synthesis. 
>
>Do any of you have experience with the documentation required for 
>newly synthesized chemicals?  All of the chemicals are for research 
>and development purposes, and all are in small quantities. 
>According to the regulations, as I understand them, we have to 
>provide notice of health risks that may be associated with exposure 
>to these newly synthesized chemicals.  But how?  Do we need to 
>generate some kind of MSDS, or is there a labeling system that is 
>used?
>
>Thank you in advance for your help.
>
>Karen Humphrey

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EHS Strategies, Inc.
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