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Previous by Date: Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations Date: Thu, 17 Feb 2011 20:17:52 -0500 Author: "Bell,Martin" |
Next by Date: Subject: Chemical Safety headlines from Google Date: Fri, 18 Feb 2011 07:46:47 -0500 Author: Ralph Stuart |
> >I advise my clients during inspections to replace any chemicals older than a year. That helps eliminate the inherently waste-like, speculative accumulation, etc practices EPA folks like to cite. I agree that that is good advice, but we advise someone who has "perfectly good" chemicals that are more than a year old that they want to keep to label them with an inspection date so that the EPA concern about their inherently waste-like nature is rebutted. We recommend that such inspections happen annually to demonstrate prudent approach in chemical inventory management. This has worked for us in some cases during a couple of different inspections, although there were some arguments that we lost on the issue as well. - Ralph Ralph Stuart, CIH Environmental Safety Manager University of Vermont Environmental Safety Facility 667 Spear St. Burlington, VT 05405 rstuart**At_Symbol_Here**uvm.edu
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