Date: Fri, 10 Sep 2004 11:53:22 -0400
Reply-To: ILPI <info**At_Symbol_Here**ILPI.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Managing Chemicals with stench characteristics
In-Reply-To: <p06020415bd676e633810**At_Symbol_Here**[]>

As author of the most popular Internet site for MSDS information at I guess I need to chime in on
this rapidly diverging thread on a couple of points:

1. 29 CFR 1910.1200 is a performance-based standard.  MSDS's have to
contain certain information, but there is no required format or
ordering.  While OSHA now recommends the ANSI format, is examining
the Globally Harmonized System and has been accepting public comments
on such issues, it will take an act of Congress to make every MSDS
have the same information in the same place.    And when that
happens, let's hope they include CAS numbers, web site addresses and
other information that is not currently required.

2. It will take folks like us lobbying their Congressional
representatives to enact "plain English" requirements for MSDSs.  You
would not believe the phone calls and emails I've received on this
topic.  That is why I created the MSDS HyperGlossary and
MS-Demystifier -   And to
get an idea of just how many folks don't understand the terms on
their MSDS's I'll point out that the MSHG section of our site
received over 212,000 page views from 77,000+ unique IP addresses
last month.   Likewise, according to this  OSHA-contracted study  "on
average, literate workers only understood about 60% of the health and
safety information on the MSDSs associated with the hazardous
chemical, in all three comprehensibility studies."

3. The HazCom standard was written so that manufacturers do not have
to perform testing on items in order to write the MSDS.  For many
small companies making simple materials such as window cleaner etc.
this works fine because they can rely on an ample body of available
data.   But when someone makes a new compound that does not meet the
"mixture" definition (see ) they have no way
to determine the toxicity etc. without expensive testing.   They have
to take their best guess and be overly cautious not just for legal
liability, but because they honestly do not know.    A plain English
requirement for MSDS's would make the manufacturer spell out that no
testing has been performed and that the recommendations for PPE etc.
they are making are based on similarities to other materials etc.
This would go a long way in making the communication of *potential*
or *unknown* hazards more accurate.

4. MSDS information is generally inaccurate.   The OSHA study I
referenced in point 2 stated "one expert panel review established
that only 11% of the MSDSs were found to be accurate in all of the
following four areas: health effects, first aid, personal protective
equipment, and  exposure limits. Further, the health effects data on
the MSDSs frequently are incomplete and the  chronic data are often
incorrect or less complete than the  acute data."   Yes, that's
ELEVEN percent.  You can start a whole new thread on how to improve
this number and the study provides a lot of food for thought.

5.  If our thousands of daily visitors could rewrite HazCom in one
way, it would be to *require* manufacturers to post all their MSDS's
on their web sites.    There has long been a call for a "national
MSDS repository", an idea that OSHA examined and discarded years ago;
this gap is certainly being filled by private industry, although it
does nothing for an employee whose employer does not subscribe to an
MSDS service.

6. MSDS's are not required for materials that do not meet the OSHA
definition of hazardous,
While almost anything can meet that minimum definition, companies
persist (usually because of downstream customer demands) in putting
out sheets for non-hazardous materials instead of simply supplying a
letter that they have determined under 29 CFR 1910.1200 that the
material is not hazardous and, therefore, no MSDS is required.  OSHA
discourages MSDS's for non-hazardous materials but can not prevent it.

In response to a comment today,

At 11:07 AM -0400 9/10/04, Phil Anderson wrote:
>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).

Just a fine point here - consumer items used in a non-consumer
fashion *do* require an MSDS.  For example, an office worker who uses
Windex with the same frequency and duration as a consumer does not
need an MSDS.  But a window washer who uses the stuff all day does
require one.

It would be terrific if the top of every MSDS had a statement to the
effect "This information is meant for employees who may be exposed to
this material as part of their job duties or in the event of an
emergency in their workplace.   It is not meant for household
consumers who use this substance on an occasional basis."

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