I work in R&D for a small manufacturing company and was in a similar situation to yours.  Our R&D group was initially left out of the processes that the plant was involved in, permitting, MOCs, etc.  We now have a Laboratory Chemical Safety Plan that includes the SOPs for what you are describing.  By having the plan in place, we can follow the SOPs.   We only have to do MOCs when permanent renovation changes are involved.  Changing the tubing in our hoods does not require an MOC, but running a permanent vacuum line from a pump to a hood would require an MOC, we would have to have someone from the maintenance department run such a line.  Running a temporary line (such as rubber vacuum tubing from a portable vacuum pump) would not require an MOC.  As for changing gas cylinders, they are covered by an SOP in our Lab Chemical Safety Plan, so no MOC is required.

 

Hope this helps. 

 

Nickie Norton

Research Chemist

The Shepherd Chemical Company

4900 Beech Street

Norwood, OH  45212

nnorton**At_Symbol_Here**shepchem.com

513-842-9332

 

 

Notice: The information disclosed in this communication constitutes confidential and proprietary business information which is the property of The Shepherd Chemical Company.  The information is being disclosed to you and accepted by you on a confidential basis.  It is not to be disclosed by you to any third parties without the prior express written consent of The Shepherd Chemical Company.  Further, it is not to be used by you for any purpose other than for the specific purpose it was disclosed to you by The Shepherd Chemical Company.  These confidentiality and non-use obligations shall continue until such time as the information becomes generally available to the public, through no fault of your own.

 

 

 

 

I am a part of a group that is currently reviewing and updating the company’s safety standards.  The company has mainly focused on the industrial process plant in the past, designating R&D along with all administrative areas as “unclassified”.  This has allowed the lab to conduct research with minimal need for permits, MOCs, and other obstacles that are more pressing at the plant scale (kTon).  It is quite obvious that R&D is more hazardous than an office area and thus should adhere to more stringent standards.  My goal as the R&D representative is to make the laboratory as safe as possible without completely hindering progress. 

 

My question lies within the Line/Vessel Opening safety standard.  The current policy states “a permit is required before any line can be opened or removed.”  At the laboratory scale this doesn’t seem practical.  We build our vacuum/pressure/piping systems ourselves in most cases (using the appropriate glassware or stainless steel for the conditions) and often make modifications based on reaction observations and results.  It is important to note that we do not modify vessels that are rated for pressurized reactions, only the piping that feeds the gas.  Our piping systems are primarily 1/4” or 1/8” SS or copper tubing  which we cut and bend ourselves.  Is it necessary to write a permit for each modification?  Are there certain exceptions I can site when writing this standard?

 

Also, technically changing gas cylinders involves a line opening as well.  We have a lab SOP for this process.  Should a permit be required?

 

I am the CHO for my lab and a researcher, so I’d like to find a compromise that puts safety first without impeding lab work entirely.

 

Does anyone have experience with this type of situation/policy?

 

Hannah Corcoran

R&D Facility Lead

Emerald Kalama Chemical, LLC

1296 Third St NW

Kalama, WA 98625

360-673-0319  (office)

hannah.corcoran**At_Symbol_Here**emeraldmaterials.com

 

"Attitude is a little thing that makes a big difference." – Winston Churchill

 

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