Date: Thu, 9 Sep 2004 23:07:49 EDT
Reply-To: ACTSNYC**At_Symbol_Here**CS.COM
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: Managing Chemicals with stench characteristics
Comments: To: mrakas**At_Symbol_Here**

We know each other.  I trained at Smith and was one of the building planning
consultants for Polshek on the renovated art building there, if you remember.

The MSDS is an important starting point, but you need a second opinion from
someone who is not selling the stuff.  One good place to get this opinion for
about 1400 chemicals is from the New Jersey Department of Health's website.
Look for their Hazardous Substances Fact Sheets (HSFS).

You must be aware that the quality of MSDSs is so bad that OSHA is currently
holding meetings with stake holders to try to improve them.  I've been working
with an editor from the Bureau of National Affairs on this problem for some
years.  And recently, a Bureau of National Affairs reporter interviewed an OSHA
representative who said they were looking at the New Jersey HSFS as a
potential model.  Good idea.

For example, MSDSs are supposed to report the cancer ratings of IARC, NTP and
OSHA.  And many MSDSs will say "not considered a carcinogen by IARC, NTP and
OSHA" which people will misinterpret to mean the stuff does not cause cancer.
Instead, the most common reason for there being no cancer ratings is that the
chemical has never been studied for cancer effects.

The New Jersey fact sheets will tell users when the stuff has never been
evaluated--not only for cancer, but for reproductive hazards and chronic hazards
in general.  And considering that there are about 80,000 chemicals in use in
our products and there is solid cancer data on only about 500 chemicals, this is
going to be the case far more often than not.

Manufacturers NEVER tell their customers that the chemicals in their products
have never been studied for cancer, reproductive and other long term effects.
 This might cause their customers concern.  Gosh, mustn't do that.

It is this kind of finagling that we see on even the best MSDSs from those
fortune 500 Companies you talk about.  And then we get to the thousands of
smaller companies and the quality plummets even further.  MSDSs are a mess.

And as for EPA's new chemical review process, EPA only exercises control in
the premanufacture phase on a handful of types of chemicals. I read the Federal
Register daily and follow these determinations with interest.   Somewhere
between 1000 and 2000 new chemicals are created yearly, and I think under 50 are
controlled during premanufacture.

And as I pointed out above, EPA and OSHA say nothing about the tens of
thousands of chemicals about which we know nothing that are labeled without warnings
or as "nontoxic."   I think in the lecture I did at Smith I mentioned
1,2-dihydroxyanthraquinone (alizarin crimson) as an example of a "nontoxic" art
pigment when anthraquinone itself and 5 substituted anthraquinones including
1,8-dihydroxyanthraquinone are all listed by NTP as R.

Monona Rossol, M.S., M.F.A.,
industrial hygienist
Arts, Crafts & Theater Safety, Inc.
Safety Officer,
United Scenic Artist's, Local 829
International Alliance of Theatrical Stage Employes (IATSE)
181 Thompson St., #23
New York NY 10012-2586     212/777-0062

In a message dated 9/9/04 3:09:11 PM Eastern Daylight Time,
mrakas**At_Symbol_Here** writes:
> Monona--
> While you make several very good points about isocyanates, and I am not
> familiar with this particular product, I believe you do those who write
> MSDS's a great disservice, and your advice could in fact dissuade people
> from reading the MSDS or warning labels.  ("MR:  If you get your hazard
> data from the people selling the product, then I have a car I want to
> talk to you about.")  Why bother reading it if "THEY" are just going to
> lie about it?
> In a former life, I managed an EH&S group for a Fortune 500 company.
> My regulatory group, and our legal department, were never hesitant about
> disclosing hazards.  Even the business people understood the necessity.
> CIH's and CSP's, along with toxicologists and those who understand OSHA
> Hazcom, are well aware of their responsibilities, and in industrial
> meetings I never found anyone from a good-sized company who did not take
> this responsibility very seriously.
> It would be much more productive for 'MRSAFETY MAN' to contact Dow
> again, and ask to speak with their regulatory specialist for this
> product.  When he has that person on the line, he should explain some of
> the excellent technical points you raise below, and ask if perhaps the
> industrial hygienist who is responsible for the Dow workers who produce
> this material could be in a conference call.  I don't know why Dow did
> not highlight the isocyanate issue--it can be a problem for asthmatics
> as well as those who develop a sensitivity--and the weird thing about
> isocyanates is that at least some of them can cause respiratory
> sensitivity through SKIN contact.   In my experience, Dow takes good
> care of its workers (I did work for them as a student intern 20 years
> ago, but not since) and they may have data that led them to write the
> MSDS and label as they did.  If MrSafetyMan doesn't ask, he is going on
> incomplete information.
> Also, if you create a new molecule for commerical (as opposed to
> drug/food/cosmetic use) it is NOT unregulated---EPA has a
> premanufacturing review process.  They can stipulate all sorts of
> warnings on labels/restrictions on consumer use, etc. as a condition of
> approval.
> My 2 cents' worth, and this is only my personal opinion, not that of my
> employer or any organization to which I belong.
> Margaret
> Margaret A. Rakas, Ph.D.
> Manager, Inventory & Regulatory Affairs
> Clark Science Center
> Smith College
> Northampton, MA. 01063
> p:  413-585-3877
> f:

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