Re[2]: MSDS for radiological hazards?

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     The way that I understant MSDS, having spent about three years this 
     decade playing at being the Health and Safety Manager for a consulting 
     firm at a DOE facility, the MSDS is written following certain vague 
     generalities and specific ambiguities specified in Title 29 Code of 
     Federal Regulations Part 1910.1200(g).  This requires that certain 
     physical and chemical characteristics be listed, however, the criteria 
     for where these characteristics is left pretty much to the 
     manufacturer of the hazardous material.  Tritium is listed in Title 49 
     Code of Federal Regulations Part 172.100, Appendix, Table 2 (under 
     Hydrogen-3, not tritium) with a RQ value of 100 Curies.  Apparently, 
     this was enough for the manufacturer to consider the CYA game for 
     himself, and an MSDS was made up for tritium concerning itself with 
     the radiological aspect, in lieu of the chemical aspect.  (Let's face 
     it, the human anatomy can not really determine H1 from H3, especially 
     when the H3 is in H20 [having fun yet?]).  
     
     Therefore, the manufacturer, in considering tririum to be a hazardous 
     substance, as listed in 49CFR172.101, and not wanting to face the 
     wrath of a Government agency (which is probably shut down as 
     non-essential while the Senate and House determines just how bad Billy 
     Clinton really is) decided to make a MSDS to cover his *** for a 
     material that most of us RADSAFErs consider a nuisance.
     
     Hope this thoroughly muddles the question.
     
     R.R.Goodwin - Senior Health Physicist - Nuclear Material Safety
     Ohio Dept. of Health, Bureau of Radiation Protection
     Ronald_Goodwin@health.ohio.gov
     


______________________________ Reply Separator _________________________________
Subject: Re: MSDS for radiological hazards?
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    1/4/96 2:31 PM


Happy New Year RADSAFERS,
     
        Every shipment of RAM leaving NASA - Goddard Space Flight Center 
has a copy of a "MSDS" (only titled that way for HAZMAT people).  We use 
the standard format shown in the USDOT Emergency Response Guidebook 
which corresponds to the type of RAM being shipped.  We do this as a CYA 
thing. (You x-military people should know that acronym).
     
************************* /^\   /^\ *****************************   
Tad Blanchard            /___\ /___\  NASA-Goddard Space Flt Ctr    
Nat'l Health Svc, Inc         O       Greenbelt, Maryland           
Sr Health Physics Tech       / \      Phone: 301-286-9157           
                            /___\                                   
              Tad_Blanchard@ccmail.GSFC.NASA.gov                    
*****************************************************************   
     
     
     
     
     
     
     
______________________________ Reply Separator _________________________________
Subject: MSDS for radiological hazards?
Author:  radsafe@romulus.ehs.uiuc.edu at Internet 
Date:    1/4/96 10:20 AM
     
     
 I have just received a Material Safety Data Sheet (MSDS) from a vendor for a 
 device containing tritium; this MSDS addresses the radiological hazards rather 
 than chemical/physical hazards. It has been my understanding that OSHA 
 specifically exempts radioactive materials from MSDS requirements. Can anyone 
 confirm this and provide me with a reference citation for this exemption?
     
      Bruce Pickett
      The Boeing Company
      Seattle, WA
      shea136@kgv2.bems.boeing.com
     
 "Welcome to my nightmare."
                          - Alice Cooper