Date: Tue, 18 Jan 2011 07:15:39 -0600
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: Beth Shepard <Beth.Shepard**At_Symbol_Here**SIAL.COM>
Subject: Re: access to chemical stockroom
In-Reply-To: <AANLkTimSLYL1gCC7qF2-4zO4hF+EFfY9NZ=m3gS0F+ej**At_Symbol_Here**mail.gmail.com>

Good morning--

Aside from the hazard issues, there may also be a regulatory problem with 
open access to certain chemicals (ex. DEA List I & II chemicals). You'd 
need to check the federal/state/local regulations (DEA, Dept. of Homeland 
Security, TTB, etc.) on what security they require, what reports need to 
be filed, etc. My knowledge of these regs. is based upon the seller's 
responsibilities, not the end-users responsibilities. 

With open access, you're relying on the faculty to accurately complete the 
log, (with the potential for excuses such as ...I'm in a hurry, I'll come 
back & fill in the log later; I think the log's another wasted exercise, 
why should I waste my time; ...)If the access is limited to dedicated 
stockroom personnel, filling out that log & keeping the inventory balanced 
would be/should be part of their job.

In my personal opinion, at a minimum, removing chemicals from a storeroom 
should involve as much documentation as removing a book from the library. 

Beth

Beth Shepard / Technical Compliance Specialist 
Regulatory Compliance 
6000 N. Teutonia Ave. / Milwaukee, WI 53209 / USA 
P: (414) 438-3850, x5471 
sigma-aldrich.com 



Patrick A Ceas  
Sent by: DCHAS-L Discussion List 
01/17/2011 09:10 PM
Please respond to
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[DCHAS-L] access to chemical stockroom




Hi all,

I know that this or a similar question has been asked before, but please 
allow me to ask it once again in a simplified form: For your central 
chemical storeroom, how is access to chemicals controlled?   (assume that 
the person who is picking up the chemical is wearing appropriate PPE & 
uses an appropriate transport container):
(a) Open Access: all faculty are allowed to enter and take what they want 
as long as they log the user & amount.
(b) Closed Access: no faculty are allowed to enter, and only a few 
individuals (e.g., trained stockroom employees) have access to the 
chemicals; faculty request a chemical, and that chemical(s) is either 
delivered or can be picked up from a check-out window.
(c) Limited Access: all faculty have "Open Access" to a subset of 
chemicals with "lower" hazard ratings and they can simply log out the 
amount taken; however, for chemicals with "higher" hazard ratings (e.g., 
NFPA of 3 or 4) it is "Closed Access."

Thanks.  Feel free to reply directly to me or to the list.

Pat

-- 
Dr. Patrick Ceas
312 Regents Hall of Natural Sciences
St. Olaf College
Northfield, MN 55057
507-786-3560


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text/html;
Good morning--

Aside from the hazard issues, there may also be a regulatory problem with open access to certain chemicals (ex. DEA List I & II chemicals). You'd need to check the federal/state/local regulations (DEA, Dept. of Homeland Security, TTB, etc.) on what security they require, what reports need to be filed, etc. My knowledge of these regs. is based upon the seller's responsibilities, not the end-users responsibilities.  

With open access, you're relying on the faculty to accurately complete the log, (with the potential for excuses such as ...I'm in a hurry, I'll come back & fill in the log later; I think the log's another wasted exercise, why should I waste my time; ...)If the access is limited to dedicated stockroom personnel, filling out that log & keeping the inventory balanced would be/should be part of their job.

In my personal opinion, at a minimum, removing chemicals from a storeroom should involve as much documentation as removing a book from the library.

Beth

Beth Shepard / Technical Compliance Specialist
Regulatory Compliance
6000 N. Teutonia Ave.
/ Milwaukee, WI 53209 / USA
P: (414) 438-3850, x5471

sigma-aldrich.com


Patrick A Ceas <ceas**At_Symbol_Here**STOLAF.EDU>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>

01/17/2011 09:10 PM
Please respond to
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>

To
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
cc
Subject
[DCHAS-L] access to chemical stockroom



Hi all,

I know that this or a similar question has been asked before, but please allow me to ask it once again in a simplified form: For your central chemical storeroom, how is access to chemicals controlled?   (assume that the person who is picking up the chemical is wearing appropriate PPE & uses an appropriate transport container):
(a) Open Access: all faculty are allowed to enter and take what they want as long as they log the user & amount.
(b) Closed Access: no faculty are allowed to enter, and only a few individuals (e.g., trained stockroom employees) have access to the chemicals; faculty request a chemical, and that chemical(s) is either delivered or can be picked up from a check-out window.
(c) Limited Access: all faculty have "Open Access" to a subset of chemicals with "lower" hazard ratings and they can simply log out the amount taken; however, for chemicals with "higher" hazard ratings (e.g., NFPA of 3 or 4) it is "Closed Access."

Thanks.  Feel free to reply directly to me or to the list.

Pat

--
Dr. Patrick Ceas
312 Regents Hall of Natural Sciences
St. Olaf College
Northfield, MN 55057
507-786-3560

This message and any files transmitted with it are the property of Sigma-Aldrich Corporation, are confidential, and are intended solely for the use of the person or entity to whom this e-mail is addressed. If you are not one of the named recipient(s) or otherwise have reason to believe that you have received this message in error, please contact the sender and delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this e-mail is strictly prohibited.

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