Thanks Harry, I knew someone would get this. OSHA doesn't require any specific ventilation equipment. OSHA requires 1) a chemical exposure risk assessment after which the employer must provide 2) whatever works to keep exposure below any action level or PEL. And since the PPE rules require engineering controls when "feasible" rather than respirators, that leaves the obvious conclusion that ventilation is needed.

For chemists, the best solution is the fume hood. In art where work in the open is needed, usually some other local exhaust system such as a spray booth, slot hood, flex duct, etc.

In the case of labs, this is complicated by the vast numbers of different chemicals that might be used. No one would want to have people work with each of these chemicals in the open so they could do a personal monitoring to assess the risk for each. So the assumption is made that snorting solvents is probably not a good thing and using all the nasty stuff in a hood saves time and money because no personal monitoring risk assessment is usually needed.

I really think the desire to see a written requirement for fume hoods is generated by the inability of many of our administrators to follow this logical reasoning. Most seem to need (or demand) short, simple rules under the heading: "achtung."

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President: Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St., #23

New York, NY 10012 212-777-0062

actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

-----Original Message-----
From: Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Aug 24, 2017 5:16 am
Subject: Re: [DCHAS-L] Fume Hood Regs

Monique,

The short answer is that there are no regulations as to when a hood is required. Russ has it down, with the inclusion that the Laboratory Standard employers to maintain exposure levels below the Action Level (if one is present) or PEL (if one is present) for the chemicals being used in a laboratory.

ANSI Z9.5 is not a regulation: It is an industry consensus standard or best management practice.

Harry

On Wed, Aug 23, 2017 at 3:20 PM, Russ Phifer <rphifer**At_Symbol_Here**wcenvironmental.com> wrote:

The correct answers to which regulations may help you decide when a ducted fume is needed -

1. Whenever your Chemical Hygiene Plan says so.

2. The OSHA Laboratory Standard clearly implies that a vented hood should be used when volatile or toxic substances are present which may result in an exposure above PELs or a chemical health or physical hazard that may be eliminated by engineering controls.

3. The OSHA General Duty Clause indicates it is the employer's obligation to safe workplace for all employees. That would logically include providing appropriate controls, including proper ventilation.

Russ

Russ Phifer, Executive Director

National Registry of Certified Chemists

125 Rose Ann Lane

West Grove, Pennsylvania 19390

610-322-0657

800-858-6273 FAX

rphifer**At_Symbol_Here**nrcc6.org

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Smallbrock, Margaret A.
Sent: Wednesday, August 23, 2017 3:35 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Fume Hood Regs

I would be interested in this as well.

Margaret Smallbrock

Campus Environmental Health and Safety Manager Environmental Health & Safety South Dakota School of Mines

501 East St. Joseph Street

Rapid City, SD 57701-3995

605-394-6020

605-394-5837 FAX

Margaret.Smallbrock**At_Symbol_Here**sdsmt.edu

-----Original Message-----

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Wilhelm, Monique

Sent: Wednesday, August 23, 2017 12:15 PM

To: DCHAS-L**At_Symbol_Here**PRINCETON..EDU

Subject: [DCHAS-L] Fume Hood Regs

Does anyone know of any regs that specifically state WHEN fume hoods are required, specifically ducted hoods?

Thank you,

Monique

Sent from my Verizon, Samsung Galaxy smartphone

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