Bob and others:

This is an interesting problem, and not so simply answered as it might seem.
There are cut-offs for the precentage composition of a "mixture" below which
the specific chemical is not required to be listed on a container label, nor
mentioned on the MSDS.  This is assuming that the mounts can be called a
"mixture", which is stretching the definition to begin with.  I would argue
that the mounts are "items".  Since you do not apply the arsenic, don't buy,
manufacture, store or use it( as a raw material), the applicability of
labelling requirements, OSHA 1200 regulations, or SARA Title III
requirements (under which the Fire Department is asking to see MSDS's)is
questionable at best.

I think the suggestion that you talk with  the FD people responsible (that
is, the Fire Marshall, not one of the Inspectors) is a good one.  But put
whatever agreement you come to in writting, otherwse next year, a different
inspector could well cite you.

Also, it really doesn't matter, in this case, which arsenic salt was used.
All are inorganic arsenicals, and the danger in case of fire is exactly the
same, as is the nature of the PPE (Personal Protective Clothing) required
for the firefighters.  Arsenic contamination of water used to fight the fire
is also a concern, but a secondary one.

You might want to obtain the asistance of an industrial hygienist in
discusing this with the Fire Department.  Just because the laws may not
actually apply doesn't mean (1) that it is not a legitimate concern for the
firefighters, or (2) that they can't or won't make life difficult for you if
they don't understand the true situation.

In 20+ years as an industrial hygienist, I constantly repeated this mantra
to my clients:  Talk with the Fire Department.  Don't wait until they come
to inspect you, or respond to your emergency.  This is especially important
in the museum setting, as how they conduct themselves when you DO have that
emergency can make a huge impact on how much or how little damage your
collection and data suffer.

Richard White
Curator/Acting Director
The International Wildlife Museum

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