Staticmaster® Brushes and Ionizing Units
Regulatory requirements
There is no such thing as "harmonization" of governmental regulations on the
use of the Staticmaster antistatic products from country to country.
Therefore it is most important for you to check and confirm just what are the
requirements in the country to which the product would be shipped and used.
United States:
The following statement, which is presented a an Material Safety Data Sheet
(MSDS) Exclusion Statement, is applicable only in the USA. While it might be
presented to regulatory bodies in other countries, we can not guarantee that such
permissions would be given.
The air ionizing devices manufactured under the name of Staticmaster®
are excluded from any requirement to supply Materials Safety Data Sheets
(MSDS). The exclusion is set forth in 29 CFR Ch. XVII (7/1/88 Edition)
S1910.1200 Hazard Communication Section 6, which states "This section does
not apply to :" (iv) Articles.
"Article" means a manufactured item: (i) which if formed to a specific shape
or design during manufacture; (ii) which has end use function(s) dependent
in whole or in part upon its shape or design during end use; and (iii) which
does not release, or other wise result in exposure to, a hazardous chemical,
under normal conditions of use.
The manufacturer of the Staticmaster line of products will not issue MSDS
for the explicit reason stated above. It is their position that to do so
would mislead both their own and SPI's customers, implying a hazard which
does not exist. All required instructions are included with each shipment.
Furthermore, OSHA has prepared regulations regarding the use of radioactive
materials in industrial environments (29 CFR 1910). Such regulations are
essentially a restatement of US NRC regulations regarding such materials.
The OSHA regulations specifically state that individuals using radioactive
materials under the terms of a valid NRC or Agreement State License are
exempt from OSHA regulations with regard to the use of our nuclear static
eliminators. However, the end user has the responsibility to use the
devices in accordance with the instruction sheets provided with the devices.
Our intent was to provide this explanation as to why there is no MSDS
provided with these products. Such requests do arise from time to time and
in some institutions, the inability to supply an MSDS has resulted in a
decision of non-use of the Staticmaster line of products. We believe that
is unfortunate since these items are of incomparable quality and in many
darkroom situations are literally something that one just can not do without.
Canada:
In order to possess any polonium 210, no matter how small the quantity or
lowness in radioactivity, a special license is required. The fact that the
license covers holder who might have on hand up to 10 millicuries at one
time, and the Staticmaster products have only a few microcuries, seems to
not make any difference. A license is required in Canada and the cost is
presently CAN $700.00.
Other countries:
We don't know what might be the regulations in other countries with regard
to the Staticmaster products that contain only a few microcuries of
radioactivity. Please check with your local authorities if in doubt.
Remember that SPI Supplies can not be responsible for knowing the details of
all local regulations in all countries. The burden of responsibility for
doing that is completely on the shoulders of the customer.
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Wednesday May 14, 2008
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