fume hood variance on letterhead - University of California, Davis

UNIVERSITY OF CALIFORNIA, DAVIS
BERKELEY · DAVIS · IRVINE · LOS ANGELES · RIVERSIDE · SAN DIEGO · SAN FRANCISCO SANTA BARBARA · SANTA CRUZ
ENVIRONMENTAL HEALTH & SAFETY
UNIVERSITY OF CALIFORNIA
DAVIS, CALIFORNIA 95616-8586
(530) 752-1493
FAX: (530) 752-4527
January 2, 2008
Len Welsh, Chief
Division of Occupational Safety and Health
Department of Industrial Relations
1515 Clay Street, Suite 1901
Oakland, CA 94612
Dear Mr. Welsh
The Universityof California Davis requests a temporary <strong>variance</strong> from Title 8, California Code of
Regulations, §5154.1 (e)(3)(A), as allowed under the California Labor Code. Title 8, §5154.1
(e)(3)(A) requires all laboratory <strong>fume</strong> <strong>hood</strong>s, by Jauary 1, 2008, be equipped with a quantitative
airflow monitor that continuously indicates whether air is flowing into the exhaust system during
operation. Due to constraints and challenges scheduling the installation contractor and coordinating
the installation of the monitors with class schedules and active research occurring in <strong>fume</strong> <strong>hood</strong>s, the
University of California Davis hereby requests an effective date of October 1, 2008 for the
installation of the quantitative flow monitors on all required laboratory <strong>fume</strong> <strong>hood</strong>s at the University
of California Davis. Costs for compliance with this new regulatory requirement will be in excess of
$100,000.
Existing Inventory and Progress to Date:
The options for monitors have been reviewed and, in cooperation with Environmental Health and
Safety and Facilities Management personnel, the optimal monitor to be installed identified. UC
Davis currently has a total of 1600 laboratory <strong>fume</strong> <strong>hood</strong>s. All <strong>fume</strong> <strong>hood</strong>s requiring monitors will
be identified by February 15, 2008 and installation of the first 60 or so monitors completed. As of
January 1, 2008, buildings in the campus “core” have been surveyed with 254 <strong>fume</strong> <strong>hood</strong>s requiring
monitors identified. Surveys of outlying buildings continues.
Compliance Schedule:
The University of California Davis proposes the following compliance schedule for the installation
of the quanitative flow monitors on laboratory <strong>fume</strong> <strong>hood</strong>s:
• By January 1, 2008 a contractor engaged to effect installation and the first 100 monitors
ordered.
• By February 15, 2008, have all <strong>fume</strong> <strong>hood</strong>s that require a monitor identified.
• By May 15, 2008, a minimum of 75% of the monitors will be installed.
• By October 1, 2008, the remaining 25% of the monitors will be installed.

This schedule assumes the monitor manufacturer can meet demand and provide monitors to UC
Davis in a timely manner.
Employee Notification:
As required by the California Labor Code, the University of California Davis certifies employees
have been notified regarding this application for a temporary <strong>variance</strong> and of the employees’ right to
petition the Division of Occupational Safety and Health for a hearing regarding this temporary
<strong>variance</strong>. The <strong>variance</strong> was distributed through our Department Safety Coordinators and posted on
our Environmental Health & Safety website. Safety Coordinators were requested to distribute the
<strong>variance</strong> to their departments and post the <strong>variance</strong> request in a public location.
Qualitative monitors remain in place on all <strong>fume</strong> <strong>hood</strong>s requiring monitors not yet installed. End
users, as part of the UC Davis Injury and Illness Prevention Program and Laboratory Standard, are
trained on what to do if the end user suspects the <strong>hood</strong> is not operating properly.
In conclusion, the University of California Davis requests the Division of Occupational Safety and
Health grant a temporary <strong>variance</strong> from Title 8, California Code of Regulations, §5154.1 (e)(3)(A)
until October 1, 2008 to allow for completion of quantitative <strong>fume</strong> <strong>hood</strong> monitor installation.
If you have any additional questions feel free to contact me at (530)752-1493.
Sincerely,
Andrew Majewski, Interim Director
Environmental Health and Safety
CC: Steve Smith, Cal/OSHA
Larry Wong, EH&S UCOP
Allen Tollefson, UC Davis Facilities Management