Date: Fri, 10 Sep 2004 18:17:52 -0400
Reply-To: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: MSDS [was: Managing Chemicals with stench characteristics]
In-Reply-To: <p06020415bd676e633810**At_Symbol_Here**[]>
On Fri, 10 Sep 2004 "Mary M. Cavanaugh"  said to
the DCHAS list, in part:

>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.

And I bet the system you were working within would not permit you to call
these errors to anyone's attention, let alone actually correct them.

>Symptoms of overexposure
>routinely list "urticaria," "hyperlacrimation" and other medical terms that
>most end users don't know.

The MSDS was designed for a professional end-user who could be expected to
understand those terms.  Over the decades, it has been force-fit into other
roles where it is seen by people with a much wider educational background.
Rather than create a useful, plain language information sheet for workers
and other lacking knowledge of those terms, the MSDS intended for
physicians, industrial hygienists and toxicologists was used, with the
result you have noted.

One of the original values of an MSDS was that it was a short, succinct
summary of information, hence the six syllable words.  The more you use
plain, non-technical language in a document intended also to support the
professional community, the longer the document gets and the harder it
becomes to find what you need during an incident.

>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
>toxicity (which leaves tens of thousands of chemicals off the ingredients
>list).  This probably was done to appease industry when the reg was
>but it's time for this to change.

I don't think so.  The MSDS was originally developed (in the days of
typewriters and carbon paper) to communicate to other trained people what
information was known about a material.  In those days it seemed rather
ridiculous to even consider trying to note what was NOT known.  All those
lists of what one group or another has classified as a potential carcinogen
came along after the MSDS was developed and references to an ingredient
being on such a list were simply added as additional helpful information.

Peter Zavon, CIH
Penfield, NY


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