Oh, woe is sodium06/11/2014
MONIQUE LOWE has been on a sodium quest, and offers advice for other science technicians.
A rapid expansion of numbers in our school – especially our senior students – has seen our chemical use explode (thankfully, not literally!)
So off I went happily ordering extra chemicals. All went smoothly until it came to ordering sodium sticks.
Not only do these have a horrendous lead time, I was told I cannot order them without an Approved Handlers Certificate or Letter of Exempt Laboratory. I had heard of the need for an End Users Certificate but not of the need for an Approved Handlers Certificate or Exempt letter when ordering chemicals. Hmmmm …
I emailed the supplier back for more information and here is the reply:
Approved Handler Requirements
An Approved Handler is a person who has an Approved Handlers Certificate authorising him/her handling of certain hazardous substances. To acquire this certificate, you are required to complete a course through www.ermanz.govt.nz
Exempt Laboratory Requirement
As a school laboratory, you can apply to be exempt from Approved Handler requirements where small quantities of restricted hazardous chemicals are used for testing, teaching, research, etc. To claim exempt laboratory status, your laboratory must comply with Regulations 5-16 Exempt Laboratories Regulations (2001) (Code of Practice).
If you do meet the ‘Exempt Laboratory’ requirements, we need to be advised in writing on your school letterhead that you have declared yourselves exempt. The letter needs to make reference to Section 33 of HSNO, which stipulates that ‘small scale use of hazardous substances for research and teaching is exempt from provisions of the act provided the use occurs in a laboratory that meets the prescribed requirements’. It is important that you check your laboratory meets the requirements outlined in the Codes of Practice and stipulate this in your letter declaring your school laboratory as having Exempt Laboratory status.
Ok … obviously an Approved Handlers Certificate is out of the question, so do you have a template (such as the one for the End Users Certificate) for this ‘exempt letter’ I could use? Ah … no.
Some research was then needed as to which rules and regulations I was meant to be dealing with in our letter. I found what I assumed they were referring to on page 76 of the CoP and nothing came as a surprise there. It was all pretty much straightforward and referred to items such as signage, storage, handling, and security amongst other things that you need to comply with as an Exempt Laboratory. This information is supplied in table form, so it is very easy and convenient to read. It was also helpful in that it also indicates where in the CoP the relevant data can be found.
I was also told that this letter needed to be written by the lab manager. As many of us techies are not lab managers, this was another hurdle to climb over.
After three attempts, I finally had a letter from our lab manager, but it seemed woefully inadequate and I was getting really frustrated with this whole procedure. Surely, the powers that instigate the rules and regulations should also provide the means to carry them through? Give us a template or draft version, please!
Scitech forum was my next port of call. I asked if anyone else had had to write such a letter, and if so, what was the wording they used? Unusual for scitech comments, I only received two replies. They were both extremely helpful, but does the lack of reply mean that no one else has had to deal with this – or does no-one know exactly?
I decided to investigate a little further and rang another supplier to enquire about ordering sodium sticks. Imagine my astonishment when the second supplier told me that according to them no other paperwork was necessary to order and deliver sodium.
Where is the industry standard and conformity on this? Especially as the original supplier had emphatically told me: “Sodium metal definitely cannot be released without documentation.”
In the light of all our recent discussions on HSNA and CoP via the forum, this experience shows that we still have a very long way to go before uniformity is reached. I applaud and commend those who are working on revising this. It cannot be an easy task.
For those who may encounter this issue at a later date, I have attached the letter that I have written clarifying our school to be an Exempt Laboratory. Please feel free to use and/or amend at will. Thank you to Arwen Heyworth for her help with this, too. Please be aware that this letter must be written on your school letterhead or it will not be accepted. Click here to open the letter in pdf format.
I continue my sodium quest, but it has taken so long that now, of course, it’s so late in the year that there is no money left for it anyway. Oh, woe is sodium!!
- Monique Lowe is a science technician at John Paul College in Rotorua