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The room also contains spill control equipment and absorbent material designed to clean and decontaminate floor and equipment areas in the room following a spill. Pursuant to your office's specific citation for not having eyewash in our hazardous waste room, it is our belief and understanding that an eyewash is not required in the room given the known health hazards of the chemicals handled. As investigated by Dufour & Associates, an applicable regulatory requirement for an eyewash station is contained in the Cal/OSHA standard governing its use [8 CCR §51621. This standard requires that eyewash equipment be present in work areas where the eyes of a worker may come into contact with: a substance which can cause corrosion, severe irritation, permanent damage, or which is toxic by absorption [§5162 (a) ] None of the chemicals handled in the room are capable of causing any of the above health hazards. The two primary substances handled, MEK and MIBK, are flammable liquids, but are not corrosives, severe irritants, or toxic by absorption. In fact, in another OSHA standard [8 CCR §51551 neither MIBK nor MEK are designated as substances having skin absorption toxicity. OSHA is the regulatory agency that is most expert in matters of worker safety, and its standards should by used to interpret the DTSC's regulations that may overlap. To further support PCP's practice in this regard, Cal/OSHA has twice within the last two years, reviewed our hazardous waste room. The agency requested a couple of minor enhancements upon their first visit and verified to their satisfaction, the completion of the enhancements upon their following visit. At no time whatsoever, did OSHA require the presence of an eyewash within the room, despite having full knowledge of the chemicals within. Irrespective of our strong belief that an eyewash is not required by regulation, in the interest of cooperation with your office, PCP has placed a portable eyewash in the room, as requested. ITEM #7 LDR NOTIFICATION FORMS PCP is maintaining land disposal restriction notification forms in relation to applicable manifests.