George and others,

This reminds me of the idea - albeit fatally flawed-  that regulatory 
compliance will somehow provide us with methods and tools to create a 
safe/healthy work environment - laboratory or otherwise.

It just isn't so.

No two labs are alike, any more than two people working in a lab are.  
The performance-based expectation of this standard do not define MSDSs 
per se as all that is required, as Bob points out.  An MSDS, whether 
provided by a supplier/vendor or created by a lab itself is only one 
tool used to build and maintain the lab. It burns my buns whenever I 
encounter (all too frequently in academia, but also in industry) the 
notion that the CHP we create will somehow protect us from a variety of 
harms, whether physically or legally.  And this comes from a sector that 
does not even recognize students as "employees" covered by this 
standard...arghhh!

While I realize I am preaching to the choir, it's Friday before a three 
day weekend and I am at the end of another academic year where our 
incident rate (had it included students) would have been astronomical - 
but we have a CHP...


George Thompson, PhD. wrote:
> Bob:
>
> Your question is a good one, and your presumption of a broadbased malpractice within industry and academic labs may very well be correct. If so, one can reasonably expect an increasing number of lawsuits in this area for a number of reasons.
>
> First, the "prudent man" concept in tort law requires that employers implement worker safety and health procedures that avoid reasonably anticipated hazardous exposures. The logic you posed behind your question clearly indicates that your laboratory has violated this most basic standard.
>
> Second, the OSHA laboratory standard (29 CFR 1910.1450) defines that your laboratory Chemical Hygiene Plan (CHP:
>
>   "...sets forth procedures, equipment personal protective equipment and work practices that (i) are capable of protecting employees from the health hazards presented by hazardous chemics used in that particular workplace....[see paragraph (6) and (e)]
> In fact, the purpose of the CHP is "protecting employees from health hazards associated with hazardous chemicals in that laboratory" [Note: not in the stockroom!].
>
> Third, although the Lab Standard does refer to making "reference material...including, but not limited to Material Safety Data Sheets received from the chemical supplier" (see paragraph (f)(3)(v)], elsewhere the Standard states that hazardous "chemical substances developed in the laboratory...[require] appropriate training" [see paragraph (h)(2)(i)], and
>
>     "If the chemical substance is produced for another user outside of the laboratory [in your case, think "outside of the stockroom"], the employer shall comply with the Hazard Communication Standard (29 CFR 1910.1200) including the requirements for preparation of material safety data sheets and labeling"
>     [see paragraph (h)(2)(iii)].
>
> The bottom line: the CHP is incomplete if it does not include health hazards for solubilized solids, training will be inaequate, and required "reference material" [see paragraph (f)(3)(v)] will be missing. I believe these could be three OSHA citations.
>
> Regards,
>
> George R. Thompson, Ph.D.
> President & CEO
> Chemical Compliance Systems, Inc.
> 706 Route 15 South, Suite 207
> Lake Hopatcong, NJ 07849
> 973-663-2148 (ext. 234)
> 973-663-2378 (fax)
> georgethompson**At_Symbol_Here**chemply.com
> www.chemply.com
>
> The information contained in this e-mail is intended only for the individual or entity to whom it is addressed. Its contents (including any attachments) may contain confidential and/or privileged information. If you are not an intended recipient, you must not use, disclose, disseminate, copy or print its contents. If you received this e-mail in error, please notify the sender by reply e-mail and delete and destroy the message.
> --------------------------------------------------------------------------------
>
> ----- Original Message ----- 
> From: "Robert Belford" 
> To: 
> Sent: Thursday, May 25, 2006 12:24 PM
> Subject: [DCHAS-L] MSDS question
>
>
>   
>> We keep manufacturer's MSDS for the compounds we use in the labs.  Let's say we have solid potassium permanganate from JT Baker.
>>
>> http://www.jtbaker.com/msds/englishhtml/P6005.htm
>>
>> and we create a 0.1N solution for a lab like
>>
>> http://www.jtbaker.com/msds/englishhtml/P6008.htm
>>
>> and a student drinks a gallon of the stuff...!#$**At_Symbol_Here**!....
>>
>> Should we induce vomiting?
>>
>> The actual MSDS for the solid that we bought says no, while if we had bought the solution we made, it would say yes.  
>>
>> Now, my question is not really should we induce/not induce vomiting for this hypothetical and hopefully absurd scenario, but is it sufficient to provide manufacture's MSDS in a stock room based on the material purchased.  This scenario indicates to me that such a system is inadvisable, yet I suspect, that for obvious reasons, it is common.  I mean, you buy a chemical, and you file the manufacturer's MSDS for the chemical you bought.  That seems logical and prudent, although I doubt it is, yet, I am sure such practice is common in industry and many academic labs.  Does anyone have a written policy for filing MSDS that covers this?
>>
>> Also, are there other cases where dilution changes first aid procedures?
>>
>> Thanks,
>> Bob Belford
>>
>>
>>
>>
>>
>>
>>
>> *****************************************
>> Dr. Robert E. Belford
>> Department of Chemistry
>> University of Arkansas at Little Rock
>> 2801 S. University 
>> Little Rock, AR 72204-1099
>> rebelford**At_Symbol_Here**ualr.edu
>> 501-569-8824
>> ********************************
>> ********************************
>>
>>     

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