Check out Safety Emporium for your N95, N99, and face shield needs.
Date: Tue, 1 Mar 2011 13:07:15 -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: Mary Ellen Abel <mabel**At_Symbol_Here**MORTONSALT.COM>
Subject: Re: Photographing non-compliance
In-Reply-To: <20110301.115824.1022.0**At_Symbol_Here**webmail05.vgs.untd.com>
Just make sure that all of your photos are marked "confidential - self
audit" and circulation is kept restricted. If the pictures get into the
hands of the agency you may receive a citation for the issue.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"paracelcusbombastusvon**At_Symbol_Here**juno.com"
Sent by: DCHAS-L Discussion List
03/01/2011 12:59 PM
Please respond to
DCHAS-L Discussion List
To
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
cc
Subject
Re: [DCHAS-L] Photographing non-compliance
I do it all the time as a part of all my EHS inspections of all the plants
I visit. The picture is next to a written description of the issue and
the applicable OSHA/EPA/NFPA/building code/etc regulation. The report is
distributed to the plant manager, vice-president, and ceo. Most
appreciate the picture since it points to the issue at the time.
Lynn K
Please note: message attached
From: John Crawford McGregor
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Photographing non-compliance
Date: Tue, 1 Mar 2011 16:40:23 +0000
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
Dermatologists Hate Her
Smart Mom Uses $8 Trick to Erase Wrinkles and Look Younger Instantly
http://thirdpartyoffers.juno.com/TGL3131/4d6d33da3f6315db589st05vuc
----- Message from John Crawford McGregor on Tue,
1 Mar 2011 16:40:23 +0000 -----
To:
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject:
[DCHAS-L] Photographing non-compliance
Our department is considering photographing non-compliance in our safety
audits, and attaching these photographs to the report sent to the PI or
lab manager. Obviously, there are some issues about documenting
non-compliance is such a way. Do you all use photographs? Comments would
be appreciated.
John
John Crawford McGregor
Director - Office of Regulatory Compliance
Northern Arizona University
Peterson Hall (Bld. 22) - Room 216
PO Box 4137
Flagstaff, AZ 86011-4137
(928) 523-7258 office
(928) 523-1607 fax
(928) 220-1388 cell
nau.edu/orc
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
Rita Kay Calhoun
Sent: Thursday, February 17, 2011 1:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations
But what regulation requires that you get rid of a chemical that you
haven?t used in a year or more? There?s a difference between a
suggestion and a regulation isn?t there? In academia, especially in small
schools, upper level courses may not be taught every year. Also,
according to who is teaching the chemicals needed might change. To pay to
dispose of, and then to purchase again in four or five years a perfectly
stable chemical is wasteful, and usually we have to watch how we spend our
money. We also often need small amounts of a variety of compounds for
unknowns.
Kay
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
Kim Auletta
Sent: Thursday, February 17, 2011 2:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations
Our state Haz Waste inspectors call this "inherently waste -like" and love
to cite us for it. The researchers always argue they might need it some
day. Guess who looses?
Kim Auletta
Lab Safety Specialist
EH&S Z=6200
Stony Brook University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
FAX: 631-632-9683
EH&S Web site: http://www.stonybrook.edu/ehs/lab/
Remember to wash your hands!
From:
Jeff Your
To:
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date:
02/17/2011 02:11 PM
Subject:
Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations
Sent by:
DCHAS-L Discussion List
As regards old containers sitting on the shelf, I have heard many
'opinions' that regulators will offer.
If the bottle is expired, is there a good reason for keeping it? Is it
actively in use for research or instructional purposes?
If the bottle looks old and you cannot document its regular circulation,
then some instectors use the 'white glove' test. If I can wipe dust off
the top of the container, it's probably not being used and hasn't been for
some time. Now the question becomes, Why are you keeping it? RCRA has a
term for this: speculative accumulation.
See article below. While spec.accum. specifically addresses certain
hazardous wastes which could be recycled, it has also been applied to the
situation of holding on to lots of old chemicals with no stated present or
future purposes other than 'just in case we may need it some day'.
So, have a real good idea what is being actively used in your teaching
labs. Get rid of anything you can justify will not be used within the
next year, expired or not. This is an iterative process as profs will put
up resistance to throwing away 'perfectly good' reagents from the 1950's.
Weed regularly and a little at a time.
http://www.lion.com/newsletter/archives/2009/vol10issue47.asp
Speculative accumulation happens.
Keeping in mind that the term ?speculative accumulation? is defined only
for the purpose of determining if a material is a solid waste [40 CFR
261.2(c)], the EPA?s definition, at section 40 CFR 261.1(c)(8) starts
simply with ?A material is ?accumulated speculatively? if it is
accumulated before being recycled.?
But if we continue reading, we find that you may claim your recycling as
legitimate, and your accumulation as NOT speculative, if you meet two
conditions:
1. A feasible means of recycling the material exists, and
2. At least 75% of the material on-hand on January 1 is recycled by
the end of the year.
Remember to document everything! In any enforcement action, the burden of
proof is on the generator to show that the waste is excluded and being
legitimately recycled. [40 CFR 261.2(f)] That is, it is up to you to prove
to the regulators that the material is not being speculatively
accumulated.
On the other hand, if you stockpile hazardous secondary material, make no
arrangements to recycle it, all the while claiming that it will be
recycled later, the EPA will ask you to prove that the recycling is
legitimate, feasible, and actually happening. If you cannot do this, then
you are ?accumulating speculatively.? What happens next is, the waste will
be reclassified as solid, and possibly as hazardous, waste, and you will
get to know your local agency very well.
As always, state regulations may vary. Not every authorized state program
permits every recycling relief, and your state may have particular
standards for documenting your recycling activities.
--
Jeffrey A. Your, M.B.A.,C.S.M.M.
Science Buyer; Central Scientific
Stores and Laboratory Support Services
John Carroll University
20700 North Park Blvd.
University Hts, Ohio 44118-4578
216.397.4244 vox 216.397.1803 fax 216.496.7594 cell
---- Original message ----
Date: Thu, 17 Feb 2011 09:58:23 -0800
From: Teresa Arnold
Subject: [NAOSMM] Expiration dates of chemicals/regulations
To: dchas-l , NAOSMM
I had a question come to me from a High School, who is being dinged by a
regulatory person. I don't have a definitive answer/source. Can you
help?
One major
question I have is the idea of ?shelf life?. As a chemist, I know that
some
chemicals degrade over time. But the ones that create a hazard upon
degrading
are few and far between. What are the rules about shelf life particularly
for
inherited old chemicals? What actions are required and what are merely
suggested?
Thanks!
Teresa Arnold
George Fox University
Biology-Chemistry Lab Coordinator
tarnold**At_Symbol_Here**georgefox.edu
503-554-2724
Fax: 503-554-3884
414 N. Meridian St. #6144
Newberg, OR 97132
Just make sure that all of your phot
os
are marked "confidential - self audit" and circulation is kept
restricted. If the pictures get into the hands of the agency you
may receive a citation for the issue.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"paracelcusbomba
stusvon**At_Symbol_Here**juno.com"
<paracelcusbombastusvon**At_Symbol_Here**JUNO.COM>
Sent by: DCHAS-L Discussion List <
;DCHAS-L**At_Symbol_Here**list.uvm.edu>
03/01/2011 12:59 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
| Re: [DCHAS-L] Photographing non-comp
liance |
|
I do it all the time as a part of all my EHS inspect
ions
of all the plants I visit. The picture is next to a written descripti
on
of the issue and the applicable OSHA/EPA/NFPA/building code/etc regulation.
The report is distributed to the plant manager, vice-president, and
ceo. Most appreciate the picture since it points to the issue at
the time.
Lynn K
Please note: message attached
From: John Crawford McGregor <John.Mcgregor**At_Symbol_Here**NAU.EDU>
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Photographing non-compliance
Date: Tue, 1 Mar 2011 16:40:23 +0000
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
=5F=5F=5F=5F=5F=5F=5F=5F=5F=5F
Dermatologists Hate Her
Smart Mom Uses $8 Trick to Erase Wrinkles and Look Younger Instantly
http://thirdpartyoffers.juno.com/TGL3131/4d6d33da3f6315db589st05vuc
<
/tt>
----- Message from John Crawford McGregor <John.Mcgregor**At_Symbol_Here**NAU.EDU>
on Tue, 1 Mar 2011 16:40:23 +0000 -----
|
To:
| DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
|
|
Subject:
| [DCHAS-L] Photographing non-compliance |
Our department is considering ph
otographing
non-compliance in our safety audits, and attaching these photographs to
the report sent to the PI or lab manager. Obviously, there are some
issues about documenting non-compliance is such a way. Do you all
use photographs? Comments would be appreciated.
John
John Crawford Mc
Gregor
Director - Office
of Regulatory Compliance
Northern Arizona
University
Peterson Hall (B
ld.
22) - Room 216
PO Box 4137
Flagstaff, AZ 86011-4137
(928) 523-7258 &
nbsp;office
(928) 523-1607 &
nbsp;fax
(928) 220-1388 &
nbsp;cell
nau.edu/orc
From: DCHAS-L Discussion List [ma
ilto:DCHAS-L**At_Symbol_Here**list.uvm.edu]
On Behalf Of Rita Kay Calhoun
Sent: Thursday, February 17, 2011 1:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulatio
ns
But what regulation
requires
that you get rid of a chemical that you haven’t used in a year or mor
e?
There’s a difference between a suggestion and a regulation isn
’t
there? In academia, especially in small schools, upper level courses
may not be taught every year. Also, according to who is teaching
the chemicals needed might change. To pay to dispose of, and then
to purchase again in four or five years a perfectly stable chemical is
wasteful, and usually we have to watch how we spend our money.
We also often need small amounts of a variety of compounds for unknowns.
Kay
From: DCHAS-L Discussion List [ma
ilto:DCHAS-L**At_Symbol_Here**list.uvm.edu]
On Behalf Of Kim Auletta
Sent: Thursday, February 17, 2011 2:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulatio
ns
Our state Haz Waste inspectors call this
"inherently waste -like" and love to cite us for it. The research
ers
always argue they might need it some day. Guess who looses?
Kim Auletta
Lab Safety Specialist
EH&S Z=6200
Stony Brook University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
FAX: 631-632-9683
EH&S Web site:
http://www.stonybrook.edu/ehs/lab
/
Remember to wash your hands!
| From:<
font size=3 face="Times New Roman">
| Jeff Your <jyour**At_Symbol_Here**JCU.EDU&g
t;
|
| To:
| DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
|
| Date:
| 02/17/2011 02:11 PM
|
| Subject:
| Re: [DCHAS-L] [NAOSMM] Expiration dates of
chemicals/regulations
|
| Sent by:
| DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.
UVM.EDU> |
As regards old containers sitting on the shelf, I have heard many 'opinions'
that regulators will offer.
If the bottle is expired, is the
re
a good reason for keeping it? Is it actively in use for research
or instructional purposes?
If the bottle looks old and you
cannot document its regular circulation, then some instectors use the 'white
glove' test. If I can wipe dust off the top of the container, it's
probably not being used and hasn't been for some time. Now the questi
on
becomes, Why are you keeping it? RCRA has a term for this: speculative
accumulation.
See article below. While s
pec.accum.
specifically addresses certain hazardous wastes which could be recycled,
it has also been applied to the situation of holding on to lots of old
chemicals with no stated present or future purposes other than 'just in
case we may need it some day'.
So, have a real good idea what is
being actively used in your teaching labs. Get rid of anything you
can justify will not be used within the next year, expired or not. Th
is
is an iterative process as profs will put up resistance to throwing away
'perfectly good' reagents from the 1950's. Weed regularly and a little
at a time.
http://www.lion.com
/newsletter/archives/2009/vol10issue47.asp
Speculative accumulation happens.
Keeping in mind that the term &#
8220;speculative
accumulation” is defined only for the purpose of determining if a mat
erial
is a solid waste [40 CFR 261.2(c)], the EPA’s definition, at section
40
CFR 261.1(c)(8) starts simply with “A material is ‘accumulated
speculatively’
if it is accumulated before being recycled.”
But if we continue reading, we f
ind
that you may claim your recycling as legitimate, and your accumulation
as NOT speculative, if you meet two conditions:
1. A
feasible means of recycling the material exists, and
2. At
least 75% of the material on-hand on January 1 is recycled by the end of
the year.
Remember to document everything!
In any enforcement action, the burden of proof is on the generator to show
that the waste is excluded and being legitimately recycled. [40 CFR 261.2(f
)]
That is, it is up to you to prove to the regulators that the material is
not being speculatively accumulated.
On the other hand, if you stockp
ile
hazardous secondary material, make no arrangements to recycle it, all the
while claiming that it will be recycled later, the EPA will ask you to
prove that the recycling is legitimate, feasible, and actually happening.
If you cannot do this, then you are “accumulating speculatively.̶
1; What
happens next is, the waste will be reclassified as solid, and possibly
as hazardous, waste, and you will get to know your local agency very well.
As always, state regulations may
vary. Not every authorized state program permits every recycling relief,
and your state may have particular standards for documenting your recycling
activities.
--
Jeffrey A. Your, M.B.A.,C.S.M.M.
Science Buyer; Central Scientific
Stores and Laboratory Support Services
John Carroll University
20700 North Park Blvd.
University Hts, Ohio 44118-4578
216.397.4244 vox 216.397.1803 fax 216.496.7594
cell
---- Original message ----
Date: Thu, 17 Feb 2011 09:58:23 -0800
From: Teresa Arnold <tarnold**At_Symbol_Here**georgefox.edu>
Subject: [NAOSMM] Expiration dates of chemicals/regulations
To: dchas-l <dchas-l**At_Symbol_Here**list.uvm.edu>, NAOSMM <naosmm**At_Symbol_Here**mailman.ric
e.edu>
I had a question come to me from a High School, who is being dinged by
a regulatory person. I don't have a definitive answer/source. Can
you help?
One major
question I have is the idea of “shelf life”. As a chemist
, I know
that some
chemicals degrade over time. But the ones that create a hazard upon
degrading
are few and far between. What are the rules about shelf life particul
arly
for
inherited old chemicals? What actions are required and what are merel
y
suggested?
Thanks!
Teresa Arnold
George Fox University
Biology-Chemistry Lab Coordinator
tarnold**At_Symbol_Here**georgefox.edu<
/font>
503-554-2724
Fax: 503-554-3884
414 N. Meridian St. #6144
Newberg, OR 97132
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