Can’t speak to common practices in Academia.

 

In Industry  chemical approval processes are standard practice. 

 

My comments are in purple italics.

 

Our EH&S officer has decided that we have to send him the SDS for every chemical we are going to purchase yes, this is required by law unless your employer has less than ten employees at the facility .  Academic laboratories may have some exemption of which I am unaware of adherence to the OSHA Laboratory standards which require a CSP but if the Employer has more than 10 employees general OSHA still applies and that means that OSHA 1910..1200 is applicable, which still requires the chemical inventory so that he can review it before we are allowed to purchase the chemical. BEFORE a substance is allowed on site it should be reviewed by someone knowledgeable  in waste disposal requirements,  regulatory reporting requirements and hazards of the substance.   That person will need to know the intended use of the product and the quantity of the substance coming into the inventory.   It would also be incumbent on the reviewer(s) to verify that the end user has everything needed to accommodate any special handling, storage or training requirements.   This includes adding new standard operating procedures that may not be in the site Chemical Hygiene Plan (CHP) or  new training requirements from OSHA 1910.1200 

  Then, he wants us to send him the SDS that came with the chemical. Sometimes the SDS that arrives in the package with the chemical is not the same one that the purchaser gave to the reviewer.  This can be problematic for many reasons, perhaps there was a mix up in orders or perhaps it is a mixture not a pure chemical and the composition or percentage of ingredients changed slightly and this can make a difference in disposal, handling or storage requirements.

 

Is this a standard practice? In Industry yes I can see reviewing SDS for very hazardous substances, but even for chemicals sodium chloride and sodium bicarbonate? What a chemist considers a “hazardous substance” what I as an Industrial Hygienist considers a “hazardous substance” and what a regulatory agency considers a “hazardous substance” are three different things, so one must not only be able to evaluate the risk associated with the substance but be knowledgeable in what laws are applicable.  And those laws change. State and County laws can be  more nimble than fed laws.  What was fine last year may have a new reportable quantity this year.   Many researchers/instructors don’t  want to spend all their free time keeping up with current Federal/State/County laws on substances hence when one has the luxury they hire an  EHS person to do that.  I can understand his reviewing the SDS for substances we've never previously used on campus.  However, I think he'll drive himself (and us) crazy if he looks over every single SDS every time we make a purchase.  Certainly the approval process should make provisions for predefined amounts and uses of previously reviewed substances.  Though he should still  conduct periodic reviews of the inventory and still receive the SDS that comes with each shipment to make sure that nothing has changed, suppliers do update SDSheets periodically if it is a different supplier you should have that supplier’s SDS on file too.

 

 

I fought to get the administration to allow us to make purchases with a credit card so we could make purchases shortly before we used chemicals in class.  This procedure let us order smaller quantities and has helped us reduce our inventory, since we no longer had to "over purchase", just to guarantee that we would have enough material for our classes should the purchasing paperwork get held up.   I am unfamiliar with academic purchasing processes and how much lead time and planning is needed to order supplies, but no matter how a material is ordered and purchased, whether by card or through procurement the material should go through a chemical approval process.

 

 

Good luck with your budding chemical approval process.   Talk to the EHS Officer, if he is wise, he will be willing to hear any suggestions that  you and other  end users have,that will make both your lives easier and the chemical approval process much less painful for all involved.