DCHAS-L Archives Nov 10 2010 - Re: flammable cabinet question

Date: Wed, 10 Nov 2010 17:49:58 -0500
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From: Don Abramowitz <dabramow**At_Symbol_Here**BRYNMAWR.EDU>
Subject: Re: flammable cabinet question
In-Reply-To: <C3E98B533BBA314490DC0D1C18E02317095A5703**At_Symbol_Here**pb01msx.wgipb.local>
< div style='font-family: Times New Roman; font-size: 12pt; color: #000000' >The idea that "The bottom line on this issue is that if it's mandated by law we really don't h ave a choice but to comply" could be the subject of endless philoso phical, legal, and ethical debate, but I'd like to suggest that as a practi cal matter, given the thousands of pages of regulations and consensus stand ards out there, it'd be hard to imagine there's any institution that's mana ged to comply with every last one of them (assuming one could even be aware of every requirement), and that at some point we have to choose our priori ties and be as aware as we can of the benefits, consequences, and costs of choices about regulations.

I'm not suggesting we pick and cho ose the rules we like and ignore the rest, but rather that the consequences of being out of compliance with a specific regulation are not infinite, an d that being in compliance isn't the same as being safe. In this part icular instance, I'd choose not dropping the bottles over compliance. (I'd reconsider, of course, if the penalty for the lack of a self closing door is a mandatory life sentence on the first offense.)

Also , deciding "to ignore or work around a standard or legal requirement to do something because we may not agree with it" is what keeps the entire legal syste m in business.

& nbsp; & nbsp; Respectfully,
& nbsp; Don

I see the point trying to be brought up. There are some rules and procedures out there that while addressing one problem end up causing another one. I deal with t hose issues myself on an almost daily basis.

The point I was wanting to make is that it is not up to us to decide to ignore or work around a standard or legal requirement to do something because we may not agree with it. It appears that this person's local jurisdiction has adopted at least part of NFPA 1 (Uniform Fire Code) which when discussing Hazardous Materials Storage Cabinets states in part: "doors shall be well fitted, self-closing, and equipped with a self-latching device". Some sta tes have adopted the UFC statewide while others have had only local jurisdictio ns adopt it. This isn't a simple rule or procedural issue - this is a legal compliance issue.

The bottom line on this issue is that if it's mandated by law we really don't h ave a choice but to comply and should do our part to ensure our folks can co mply in a safe manner instead of ignoring it. NFPA reviews standards on a regula r basis. I completely agreed with you when you stated that "often rules are m ade by people who are only looking at one small part of a situation". One way we can address items like this is by joining NFPA and becoming involve d in the process that updates the standards.

Do n A. Long
STS, CAIH
So uthwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Ha ll, AR 71612
870-541-4930

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]On Behalf Of Rita Kay Calhoun
Sent: Wednesday, November 10, 2010 8:14 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] flammable cabinet question

It is hard to see the sense in following "safety rules=" that cause more danger than they prevent. Often rules are made by people who are only look ing at one small part of a situation and not at all considering the overall ramifications of their dictates. Consider the post this morni ng from Ina Ahern whose local fire department is mandating the use of a tubi ng which has been shown to cause safety problems (see her post) when all tha t is needed is a program to increase awareness as to the importance of inspect ing tubing; at most a requirement that inspections occur and are documented a t regular stated intervals.

Kay

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of List Moderator
Sent: Wednesday, November 10, 2010 7:04 AM
To:< /b> DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] flammable cabinet question

From: "Long, Don" <d on.long**At_Symbol_Here**wgint.com>

Date: November 10, 2010 6:54:08 AM EST

Subject: RE: [DCHAS-L] flammable cabinet question

"I recently bought several safety cabinets, and I found that it is the state that mandates self closing doors. Luckily, we were able to purchase ones with manual doors."

This spooks me. The above statement implies that even though self-closing door s are mandated by state law (probably a UFC state) but inconvenient, you have decided to ignore the law. I hope that's not what I read.

It's hard to convince employees of the importance of safety rules and standard s when we ourselves ignore the "inconvenient" ones.

Don A. Long

STS, CAIH

Southwest Research Institute Laboratory

Pine Bluff Chemical Agent Disposal Facility

PO Box 20130

White Hall, AR 71612

870-541-4930

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