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Guidelines for care & Use of Dry Solvent Stills [Example]

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2. HMIS / NFPA Chemical Hazard Ratings on Departmental MSDS Sheets<br />

Although the OSHA Laboratory Standard is the particular law applicable to an academic<br />

laboratory setting, it should also include the requirements <strong>for</strong> hazardous chemical assessment contained in<br />

the previous standard, the Hazard Communication Standard.<br />

“....Chemical manufacturers and importers shall evaluate chemicals produced in their workplace<br />

or imported by them to determine if they are hazardous. Employers are not required to evaluate<br />

chemicals unless they choose not to rely on the evaluation per<strong>for</strong>med by the chemical<br />

manufacturer or importer <strong>for</strong> the chemical to satisfy this requirement.”<br />

“Chemical manufacturers, importers, or employers evaluating chemicals shall describe in<br />

writing the procedures they use to determine the hazards <strong>of</strong> the chemical they evaluate. The<br />

written procedures are to be made available, upon request, to employees, their designated<br />

representatives, the Assistant Secretary and the Director. The written description may be<br />

incorporated into the written hazard communication program....”<br />

“The hazard determination requirement <strong>of</strong> this standard is per<strong>for</strong>mance-oriented. Chemical<br />

manufacturers, importers, and employers evaluating chemicals are not required to follow any<br />

specific methods <strong>for</strong> determining hazards, but they must be able to demonstrate that they have<br />

adequately ascertained the hazards <strong>of</strong> the chemicals produced or imported in accordance with the<br />

criteria set <strong>for</strong>th....”<br />

“The standard’s design is simple. Chemical manufacturers and importers must evaluate the<br />

hazards <strong>of</strong> the chemicals they produce or import. Using that in<strong>for</strong>mation, they must then prepare<br />

labels <strong>for</strong> containers, and more detailed technical bulletins called material safety data sheets<br />

(MSDS).<br />

Chemical manufacturers, importers, and distributors <strong>of</strong> hazardous chemicals are all<br />

required to provide the appropriated labels and [MSDS] to the employers to which they ship the<br />

chemicals. The in<strong>for</strong>mation is to be provided automatically. Every container <strong>of</strong> hazardous<br />

chemicals you receive must be labeled, tagged, or marked with the required in<strong>for</strong>mation. Your<br />

suppliers must also send you a properly completed....MSDS....at the time <strong>of</strong> the first shipment <strong>of</strong><br />

the chemical, and with the next shipment after the MSDS is updated with new and significant<br />

in<strong>for</strong>mation about the hazards.<br />

You can rely on the in<strong>for</strong>mation received from your suppliers. You have no independent<br />

duty to analyze the chemical or evaluate the hazards <strong>of</strong> it.”<br />

(29 CFR Chpt. XVII (7-1-95 Edition), 1910.1200 and Appendices C and E).<br />

OSHA generally endorses a universal method <strong>of</strong> hazard assessment originated by the National Paint and<br />

Coatings Association.<br />

This department rates all newly received chemicals with the National Paint and Coatings<br />

Association‟s Hazardous Materials Identification System (HMIS). The laboratory manager has<br />

determined that this practice serves as a convenient system <strong>for</strong> listing individual “particularly<br />

hazardous substances” (that is, carcinogens/mutagens/teratogens/acutely toxic compounds). The<br />

HMIS system is similar in most respects to the National Fire Protection Association system (NFPA). The<br />

NFPA system lists various hazards which are included in the HMIS numerical classification already. See<br />

page 49 <strong>of</strong> Prudent Practices, 2nd edition. A commercial HMIS “Implementation Manual” is also kept in<br />

the Chemistry Department stockroom, room # 110. Both systems serve as a nationally recognized method<br />

<strong>of</strong> rating hazards. All lab chemical suppliers and manufacturers publish Material Safety Data Sheets<br />

(MSDS) <strong>for</strong> chemicals they sell and many supply HMIS / NFPA ratings either on the MSDS or the chemical<br />

bottle label.<br />

This department maintains a set <strong>of</strong> complete MSDS sheets in the stockroom, room # 110, with<br />

HMIS / NFPA ratings printed in the upper right-hand margin on the first page <strong>of</strong> each sheet set. They are<br />

153

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