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RE: MSDS



"Flaming insistence"? You must have taken my comments much more seriously than they were constructed. The war's w/ the other guys, remember? As to DoD choices, I'm happy to say I'm no longer privy to them.
 
Re. another comment I received (much more politely):
 
<<I dont think that something has to be a hazardous waste for the OSHA right to know requirements to apply.  Further, I think that OSHA has legally applicable radiation standards also...albeit ones that have not been updated since ICRP 2. >>
 
I don't believe that's what I said, but thanks for the info.

Jack Earley
Radiological Engineer

-----Original Message-----
From: Hart, Tim P GS (RASO) [mailto:harttp@raso.navy.mil]
Sent: Monday, September 30, 2002 2:16 PM
To: 'Jack_Earley@RL.GOV'; radiation@cox.net; radsafe@list.vanderbilt.edu
Subject: RE: MSDS

Jack,
 
Sorry to throw a wet towel on your flaming insistence that the twain shall never meet but it has in the DoD.  All items containing radioactive material now procured by the DoD supply system is required to come with a MSDS.  This was done for several reason such as identification, to provide shipping information and for hazard communication. 
 
I am not passing judgment on the idea just letting you know it is being done.
 

Tim Hart
Radiation Protection Manager
NAVSEADET RASO
NWS P.O. Drawer 260
Yorktown, VA 23691-0260

Commercial: (757) 887-4692
DSN:  953-4692
Fax:  (757) 887-3235

"The aging process has you firmly in its grasp if you never get the urge to throw a snowball."  Doug Larson

-----Original Message-----
From: Jack_Earley@RL.GOV [mailto:Jack_Earley@RL.GOV]
Sent: Monday, September 30, 2002 5:03 PM
To: radiation@cox.net; radsafe@list.vanderbilt.edu
Subject: RE: MSDS

1.    An MSDS is OSHA-specified as part of its right-to-know regulation; we aren't governed by them. If we were, we'd have to allow respirators any time a worker wanted one. Although they've also adopted the ALARA approach, we don't really have much in common with what they do.
 
2.    Radioactive materials aren't (generally) considered "hazardous" materials; when combined with hazardous waste, radioactive waste becomes mixed waste. So the bottom line is that there's a difference and never the twain shall meet.
 
I've mentioned before that when I taught the NRC 40-hour RSO course to the CIH crowd, they would get really upset with me right off the bat when I told them that the chemicals they worked with were much more dangerous than anything they'd run into as RSOs. By the time we finished bio effects on day two (with the risk in perspective to everyday biological risks), I had no more arguments. Of course, there was the fact that we always had to spend the first four hours on Monday on math (algebra) review . . . might have had something to do with reminding them that there were things they didn't know or remember.

Jack Earley
Radiological Engineer

-----Original Message-----
From: Mitchell Davis [mailto:radiation@cox.net]
Sent: Monday, September 30, 2002 12:42 PM
To: Radsafepost
Subject: MSDS

Good Afternoon:
 
I have been asked by a client if I have access to an MSDS (or something with similar information as would be found in a MSDS) for both ionizing and non-ionizing radiation.  I know of no such document but then I don't know everything.  If anyone knows of where I might obtain such documents or if you have developed something similar for your facility and are willing to share them I would appreciate it.  Thank you in advance.
 
Mitchell W. Davis, RRPT
Health Physicist
915-697-3523
915-349-4824 Cell
radiation@cox.net