Date: Fri, 10 Sep 2004 11:07:54 -0400
Reply-To: Phil Anderson <panderson**At_Symbol_Here**AQUASCIENCE.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Phil Anderson <panderson**At_Symbol_Here**AQUASCIENCE.COM>
Subject: Re: Managing Chemicals with stench characteristics
Comments: To: List Moderator

NOT SO-- The MSDS is a document that is written to meet the OSHA requirements regarding contact with chemicals in an industrial setting. I write MSDS on a regular basis, even when, by law, no MSDS is required. OSHA requiers an MSDS be available for each and every HAZARDOUS chemical. It also requires that the MSDS be written to address specific goals. There are two big problems with MSDS . First is that the unknowledgeable try to over-apply them and second is that in many cases they are being written to facilitate this over-application. It simply is not reasonable to try to tell everyone in the world what is in everything in the world. The problem comes when we add in consumer items, all of which are not even covered by the MSDS section of the OSHA laws. (OSHA covers only non-consumer chemicals used by employees). If the consumer protection people want to get busy and write a law that makes someone write a document that does that, fine- I don't need to address that issue here. But the MSDS is NOT intended to do this, and as I said, to attempt to do so is a major over-application of an INDUSTRIAL communications device. Phil Anderson Technical Director Aqua Science, Inc. -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of List Moderator Sent: Friday, September 10, 2004 9:45 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Managing Chemicals with stench characteristics Date: Fri, 10 Sep 2004 10:37:55 -0400 From: "Mary M. Cavanaugh" Subject: RE: [DCHAS-L] Managing Chemicals with stench characteristics While I don't think that the lack of information on MSDSs is generally intentional, if you look at the body as a whole, MSDSs are not accomplishing what OSHA intended. That is, they aren't telling people enough of what they need to know. There are good MSDSs, even very good ones, out there. But there are as many that give virtually no useful information (lots of canned generic phrases), or the information is so technical as to be useless to the material's actual users. Sometimes even the information is overly cauktions -- perhaps because of fears of liability, or perhaps because the MSDS was written for the industrial setting where the product is manufactured in huge vats, rather than for the 1/2-pint can the end-user buys. I spent almost 2 years entering MSDS information into the military's MSDS database. I remember the fire section for solid potassium salt as "flush with water". I remember seeing the MSDS for a kind of rat poison saying "keep away from children" in the precautions section and "no ingredients recognized as toxic" in the ingredients section. Symptoms of overexposure routinely list "urticaria," "hyperlacrimation" and other medical terms that most end users don't know. A lot of the problem is, in my opinion, the way the MSDS regs are written. There is no requirement to include chemicals that haven't been evaluated for toxicity (which leaves tens of thousands of chemicals off the ingredients list). This probably was done to appease industry when the reg was written, but it's time for this to change. -mmc

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