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eppur_se_muova Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 04:36 PM
Original message
DHS is coming for our chemicals ...
Edited on Fri Feb-08-08 04:37 PM by eppur_se_muova
Got this in a letter earlier:

Overview

The Department of Homeland Security has published the Chemical Facility Anti-terrorism Standards (CFATS) Interim Final Rule with a list of Chemicals of Interest (COI). The requirements of CFATS may be applicable to {school name} if our inventory of chemicals meets or exceeds the threshold quantity for the chemicals identified in the COI list. To make this determination, an inventory is needed by March 14, 2008. The COI list excludes household-type cleaners and office supplies, so many campus departments are exempt from this inventory process.

Departments that work with chemicals are requested to complete an inventory and report electronically by logging onto {web site}. Attached is a blank worksheet that can be printed on legal paper and used to record the appropriate information manually. Descriptions for the type of information in each column is included at the bottom of the blank worksheet. Once the information is gathered, please log onto the inventory web page and enter the information. When the department inventory is complete, please notify me with an email response for recordkeeping purposes.

Worksheet Form:

1) The CAS number - a unique ID number for a chemical; if there are multiple CAS numbers you have a mixtue and will not need to report this - leave blank
2) Hazard class information - should be provided on chemical labels and is identified for most chemicals as a number between 0 and 4; if this is not provided, please leave blank
3) Estimated quantity - an aggregate amount for a particular room based on a specific measurement unit
4) Units - grams, liters, gallons, pounds, etc.
5) Container- type of storage container such as metal, glass, plastic
6) notes - anything else that is important to note (brief)


By March 14th, eh? Good thing we all have so much free time on our hands.:sarcasm: DHS is requiring a lot of labor to collect this info, and no one gets paid for the extra work.

I guess the easiest way to deal with this is to slap together an inventory and not worry about accuracy. That's the drawback of asking people to work for free, guys!:finger:
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Hekate Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 04:48 PM
Response to Original message
1. Still inadequate security at the actual chemical PLANTS, though? Typical of this admin...
...burden the small guys and claim to be actually doing something about the problem.

Hekate

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spoony Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 04:54 PM
Response to Original message
2. Surprised they didn't ask how many Muslims attend the school, too.
Edited on Fri Feb-08-08 04:54 PM by spoony
Or maybe that's a question for the registrar!

Thank goodness we have agencies opearting outside any sort of regulation or oversight protecting us from freshman chemistry classes! About time they closed that loophole! :crazy:
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warren pease Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 06:21 PM
Response to Original message
3. The easiest way to deal with this...
...and the rest of these fascist proclamations that rely on the phony war on terror for legitimacy, is to shred the paperwork, put the scraps in an envelope and mail it back to the fuckers along with a single sheet of paper with a huge raised middle finger drawn on it.

Seriously, it's really long past time for a little non-compliance. Who the fuck do these creeps think they are? They didn't even exist until "the events of 9/11(tm)" created the justification to build an entire infrastructure to support repression of dissent and dismemberment of the Constitution.

They have no place in a free society; they have no business telling anyone what to do with their time; they have no right to demand anything of anybody. They could ask politely and the appropriate answer would still be a resounding FUCK YOU.

So that's one way to respond. If you're concerned about the consequences, PM me and I'll give you my address so you can send the whole sorry pile of totalitarian shit to me and I'll take care of it for you.


wp
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poisonivy Donating Member (82 posts) Send PM | Profile | Ignore Fri Feb-08-08 06:40 PM
Response to Original message
4. As long as
the places keep an up to date inventory and current MSDS sheets this really should not be that big of a deal.
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eppur_se_muova Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 06:53 PM
Response to Reply #4
5. You have any idea how many bottles of chemicals can be found in a typical research lab?
Where I went to grad school, this would have meant hundreds of entries, maybe a couple of thousand, for some groups. (One "group" of several grad/postdoc students per professor)

And it all has to be typed into their Web page ... none of this "send us a copy of what you've got" business ... not to mention that these inventories CHANGE constantly.

Some types of info, like "type of container" would not be in many inventories, and would have to be added by hand.

And it's not likely to keep us one bit safer, so it's all pretty pointless anyway. DHS is focused on LOOKING like it's doing something, while actually accomplishing next to nothing.
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poisonivy Donating Member (82 posts) Send PM | Profile | Ignore Fri Feb-08-08 06:59 PM
Response to Reply #5
6. Your right
I have no idea what a typical research lab would have, I got my 2 year degree and went to work, I did not have the luxury of being able to be a professional student. So your telling me that there is no record keeping going on in these situations? Nobody knows what chemicals are on hand and where they are stored?
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eppur_se_muova Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 07:21 PM
Response to Reply #6
8. Plenty of record keeping already-- now they want us to transcribe it all
into THEIR format, all on our own time and labor. And as I said, info like type of container is not normally included, so that will require someone to check each individual container. This has to be done separately for *each* room where chemicals are kept.

As soon as it is done, it will be out of date, since chemicals are used up as experiments are done.

Tracking chemicals *as they are purchased* could be done automatically, and already is, for the most part. But no, we have to go make a separate list of the chemicals we have, as if it's not the same as all the chemicals we've purchased.

If you think it's not all that much trouble, should I take it you are volunteering to lend a hand? Nothing is much trouble when someone else has to do it.
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poisonivy Donating Member (82 posts) Send PM | Profile | Ignore Fri Feb-08-08 07:27 PM
Response to Reply #8
9. Considering
the fact that there are no research labs anywhere near where I live no I wont be volunteering for this little exercise. Why not simply print out the list of chemicals you have on hand?
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eppur_se_muova Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 07:30 PM
Response to Reply #9
10. OK, you're obviously not reading very carefully.
As I said in the OP, we can't do it that way. NOT permitted.
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poisonivy Donating Member (82 posts) Send PM | Profile | Ignore Fri Feb-08-08 07:36 PM
Response to Reply #10
11. It does not say
Edited on Fri Feb-08-08 07:41 PM by poisonivy
that you cannot print out an existing inventory sheet, it says you should use their worksheet. You print out your inventory, transcribe it onto the worksheet, get the msds sheets and enter the info needed from them and your done. Yea it will be a pain in the ass but not nearly as bad as you seem to want to make it out to be. In my experiences anytime we had something that looked like this really turned out not to be as bad as we had originally thought.

From the OP
"Worksheet Form:

1) The CAS number - a unique ID number for a chemical; if there are multiple CAS numbers you have a mixtue and will not need to report this - leave blank
2) Hazard class information - should be provided on chemical labels and is identified for most chemicals as a number between 0 and 4; if this is not provided, please leave blank
3) Estimated quantity - an aggregate amount for a particular room based on a specific measurement unit
4) Units - grams, liters, gallons, pounds, etc.
5) Container- type of storage container such as metal, glass, plastic
6) notes - anything else that is important to note (brief)"

Ok,

number 1: any mixtures do not need reported only containers of single chemicals.
number 2: Either on the MSDS sheet or on the actual container
number 3: its not a container by container total, just an educated guess as to the quanity on hand.
number 4: self explanitory
number 5: acids are stored in glass, etc... you know what kind of containers you store your chemicals in so that is simple.

sorry if I seem snippy about this but I see something like this and remember the fun stuff I had to do when I was in the military, this is nothing. More than likely this is just some project from somebody higher up the food chain that needs to justify their job.
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Wizard777 Donating Member (1000+ posts) Send PM | Profile | Ignore Fri Feb-08-08 07:05 PM
Response to Original message
7. Household chemicles can be dangerous.
I often tell people that don't understand their true potential danger. With what is your kitchen I could level your house. With whats in your garage I could level the block.
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