Maybe in California we've had more practice with interactions with regulatory officials: we occasionally win a few.
One example that may be applied to GHS labeling requirements for other than purchased reagents is to differentiate between working solutions (defined as those in containers such as beakers, flasks that will not be used as storage and will be gone within 24 hours) and stock solutions that will be stored. In Santa Clara County and I suspect other counties in the state, we are required to label any chemical that will be stored in a container other than that which was purchased with the full chemical name (i..e., 12 M Hydrochloric Acid, and not 12 M HCl); working solutions are exempt from that requirement.
The bottom line is to work with local regulators (who provide the interpretation). Since this is a relatively new area for everyone, it may help your cause to get a consortium of those being regulated in the same room with those who regulate them.
David
PS A few words of advice: avoid sarcasm and extreme / hyperbolic examples. The humor gene may have been deleted among within the genome of some of our regulatory colleagues
David H. Silberman
Director, Health and Safety Programs
Stanford University School of Medicine
1265 Welch Road, Mail Code 5459
Medical School Office Building, Room X-104
Stanford, CA 94305
Direct Line: 650-723-6336
Office Line: 650-723-0110
FAX Line: 650-736-0179
Mobile: 650-924-0962
From: "SCOTT GOODE" <SRGOODE**At_Symbol_Here**MAILBOX.SC.EDU>
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Sent: Thursday, May 9, 2013 11:58:42 AM
Subject: [DCHAS-L] GHS labeling of secondary containers
A university in my state recently was inspected and told to provide GHS labels for solutions prepared for their students. They purchase 12 M HCl (as an example) which has the appropriate label but they prepare 0.1 M HCl for use in student labs. They were told that the 0..1 M HCl requires a GHS label.
Not that you can win an argument with regulatory officials, but in industrial and research labs we make up thousands of solutions and samples each day.
I noticed that someone quoted the Code of Federal Regulations in an earlier response to a GHS labeling question. Does the CFR address requirements on solutions made in-house?
Does a 96-well plate does need 96 tiny labels?
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Scott Goode, Professor
Department of Chemistry and Biochemistry
University of South Carolina
631 Sumter Street
Columbia SC 29208
Email: Goode**At_Symbol_Here**sc.edu
Phone: 803-777-2601
Fax: 803-777-9521
