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The new Chemical Data Reporting rule

We have yet another acronym from the Environmental Protection Agency: the Chemical Data Reporting rule (CDR). This replaces the Toxic Substance Control Act Inventory Update Rule (hold your breath – TSCA IUR). The rule requires manufacturers and importers to provide new and updated information on current production volume, manufacturing site-related data, and processing and use-related data for a larger number of chemicals than previously listed.

The reporting threshold has also been dropped from 25,000 lbs to 2500 lbs for many products. EPA says the improved information will allow it to better identify and manage risks associated with chemicals. The new reports will be required every four years instead of five.

For the first time, EPA is requiring companies to submit the information through the Internet, using EPA’s electronic reporting tool. According to the agency, online reporting will improve both data quality and EPA’s ability to use the data, as well as make it more accessible to the public.

It is this last part I’m not sure about, especially since the agency has made it more difficult for corporations to make confidentiality claims. What data is going to be made available and how? Is there a point where the volume of data available is so vast that it’s meaningless?

I also have to ask where and how importers in particular are going to get some of their data. For instance, EPA requires that:

“if a manufacturer (or importer) can’t provide the information specified because the reportable chemical substance is manufactured using a reactant having a specific chemical identity that is unknown to the manufacturer and claimed as confidential by its supplier, the manufacturer must use e-CDRweb to ask the supplier of the confidential reactant to provide the correct chemical identity of the confidential reactant directly to EPA in a joint submission.”

Uh, I’m missing something here. What if the supplier refuses to provide that information? The wording suggests simply that manufacturers and importers must “ask.”

Companies will be required to start following the new reporting requirements in the next data submission period, which will occur February 1, 2012, to June 30, 2012.

My next blog post will be from the ACS National Meeting in Denver!

To work or not to work alone in lab

Last week on ChemBark, Paul posted about the issue of working alone in lab:

I’ve got no major problem with working alone, so long as the person doing so uses good judgment in deciding what type of work is reasonable in these situations.  When alone, it is prudent to limit yourself to experiments that don’t require especially hazardous reagents, dangerous conditions, or large scales.  That said, I don’t think there are any black-and-white rules you can institute.  Experience should also enter the analysis; you don’t want to try something dodgy for the first time when you are alone.

There are a bunch of other questions that can arise with respect to any outright ban of working alone.  First off, what counts as “alone”?  The institutional policies I’ve come across aren’t specific.  Must the researchers working be located in the same bay?  The same room?  Same floor?  Same building?

We’ve tackled this issue before on The Safety Zone, most notably in a discussion with Tim Gallagher, chair of the chemistry department at the University of Bristol, in the U.K.:

Another thing Gallagher highlights about his department’s safety culture is a prohibition on working alone—something that can be tricky to get right, he says. One approach is that no one works outside of 8 a.m. and 6 p.m. because no one else will be there. Another is to get people to collaborate to enable longer or later time in the lab. In Gallagher’s department, “We have a culture where students will work with one another to enable their experiments,” he says, noting that people must work within the line of sight of another person. Having someone in an office down the hall doesn’t cut it.

On one level, I agree with Paul that the work in question should dictate the circumstances–that is, after all, what risk assessment is all about. But are there not still some fundamental rules that should be in place? I always wear my seat belt in a car, for example, even when it’s daytime, the roads are dry, and the driver is sober, well-rested, and has been driving for many years without incident. (Full disclosure: I did work alone as a graduate student, principally to collect magnetic circular dichroism spectra. I’ve also been in a car accident.) It’s not always the hazards you know about that will cause a problem, as Gallagher also illustrated:

An incident at Bristol [in 2009] left a student’s face and hands badly cut when an experiment exploded and shattered the safety glass on the fume hood. With the benefit of hindsight, Gallagher says that the most likely cause was a side reaction that produced a small amount of an alkyl peroxide, which detonated when it came into contact with a ground-glass joint. But the peroxide formation was not something anyone had foreseen.

Are there basic safety policies that you think should be in place for all labs, all the time?

Chemicals and elevators

Do you ride in the elevator with chemicals or gas tanks?

In grad school, I regularly rode in a small elevator with big (100 L?–memory is hazy on this point) tanks of liquid helium or liquid nitrogen. In hindsight, that was not the smartest idea. If the elevator had gotten stuck for some reason, I’d have been trapped in a small, poorly ventilated space with the venting tank.

Smaller amounts of liquid nitrogen could have posed a problem, too, as would any compressed gas cylinder or volatile chemical.

Some places  have dumbwaiters that allow for transport of small containers between floors. Best practice when an elevator is involved seems to be to station one person on each floor–one to put the chemical/tank on the elevator and send it off, the other to receive the delivery. One place’s policy states that this is the preferred option, and “if an attendant must accompany the container in the elevator, an escape pack supplemental breathing apparatus must be carried in the elevator.”

Do my trips with the cryogens put me in the minority? What’s the transportation culture at your school or workplace?

Does safety harm the US chemical industry?

C&EN has a meeting with its advisory board this week. One of our advisers is In the Pipeline blogger and Vertex Pharmaceuticals chemist Derek Lowe, and he blogged on Monday looking for feedback on C&EN that he could bring to us.

I was going through the comments this morning–yes, we are always open to constructive criticism–and at the very end, a few safety-related responses emerged:

Anonymous

But I regret the lack of proper investigation into the reasons why costs are so much lower in other countries. When my enviromental health and safety officer insists that I perform calorimetry on every step of a route which uses a material containing an aromatic nitro group, tells me to reduce my usage of chlorinated solvents and asks me to separate and bag/bottle all my waste into five different streams and fill in forms in triplicate to get rid of each one, is it any surprise that I choose to send that work to India where they’ll do it cheaper and quicker than I can. No questions asked about environmental standards. No questions asked about accidents in those labs.

Should I feel guilty that I know some were hospitalised last year as the result of lab fires and an uncontrolled exothermic reaction or should I just enjoy the cost savings?

AlchemX

Our foreign competitors are brutally efficient. They barely waste any time during school or on the job that does not increase their productivity. If that means discarding safety, I think they will do it. … The outsourcing is unstoppable as far as I can tell. They are faster, cheaper and even know more a lot of the time. Because they spent a lot less time becoming politically correct citizens and much more time becoming economically competitive.

A probably different Anonymous

But I actually don’t think they have to discard safety although I’m sure some do. They just have to get rid of the mindless junk of red tape that most big companies impose on their research staff, none of which makes us safer, just less competitive.

What do you think, readers? Do U.S.–and, I would think, Canadian and European–environmental health & safety requirements hinder competitiveness? If so, is that an appropriate price to pay to ensure worker and environmental well-being? Is there a better way to do it that would maintain safety but not be a drain on productivity?