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From: "Wright, Mike"
Subject: RE: [DCHAS-L] 4 Re: [DCHAS-L] MSDS for obsolete chemical
Date: January 25, 2012 2:06:29 PM EST

The SDS's will be far better. I was part of the UN committee that designed the labels and SDSs. And having reviewed thousands of MSDSs in plants, I've seen how bad they can be.

Two examples:

á One of our local unions once sent us MSDSs for essentially the same product (ceramic fiber batting) from two different suppliers. One said: "Note: this product has been associated with malignant and non-malignant neoplasms in experimental animals exposed via intraperitoneal instillation. As this route of exposure does not mimic the human experience, the significance of this finding is uncertain." The other MSDS said: "Warning Ð causes cancer." Ironically, they were much more worried about the first MSDS. They knew how to handle carcinogens, but they figured that if a supplier went to all that trouble to obfuscate the warning, the stuff must be really bad.

á I've seen numerous MSDSs that say: "This material is not hazardous under the definitions contained in 29CFR1910.1200." And then they go on to say: "Use with adequate ventilation. Use only with proper personal protective equipment and NIOSH-approved respirators. In emergencies, move victims to fresh air, summon medical personnel, and contact your local poison control center."

By the way, treating physicians should not depend solely on the SDS or the MSDS, except in emergency response. They should look at the literature.

Michael J. Wright
Director of Health, Safety and Environment
United Steelworkers
5 Gateway Center
Pittsburgh, PA 15222

Work (412) 562-2580
Cell (412) 370-0105
Fax (412) 562-2584

mwright**At_Symbol_Here**usw.org

Visit us on the web at www.usw.org

===

From: "Wright, Mike"
Subject: RE: [DCHAS-L] MSDS for obsolete chemical
Date: January 25, 2012 2:25:48 PM EST

The relevant standard is the OSHA "Access" standard, 29 CFR 1910.1020. It requires that exposure records be retained for 30 years. MSDSs are considered exposure records, in that they document the chemical identities of what employees were exposed to. However, the employer can discard the MSDS if he or she has an alternate document that lists the identity of the chemical, where it was used and how it was used. (1910.1020(d)(1)(ii)(B).

Michael J. Wright
Director of Health, Safety and Environment
United Steelworkers
5 Gateway Center
Pittsburgh, PA 15222

Work (412) 562-2580
Cell (412) 370-0105
Fax (412) 562-2584

mwright**At_Symbol_Here**usw.org

Visit us on the web at www.usw.org

===
From: ACTSNYC**At_Symbol_Here**cs.com
Subject: Re: [DCHAS-L] 4 Re: [DCHAS-L] MSDS for obsolete chemical
Date: January 25, 2012 7:09:39 PM EST

That's OSHA's wording. The SDS is a UN work. I'd to direct to the purple book. It's easy to find.

Monona

===
From: "Kennedy, Sheila"
Subject: GHS Purple book link
Date: January 25, 2012 7:18:47 PM EST
To: DCHAS-L

This is what I found today:
http://www.osha.gov/dsg/hazcom/ghs.html

_________________________________
Sheila M. Kennedy, CHO
Safety Coordinator | CHEM Teaching Laboratories
1110 Natural Sciences Bldg.
(858) 534 Ð 0221

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