Monona, thanks for that very useful reply.
Mary M. Cavanaugh CIH
University Industrial Hygienist
Occupational Health Programs Manager
Office of Environmental Health, Safety, & Emergency Management
Appalachian State University
ASU Box 32114
Date: Wed, 25 Jan 2012 09:55:43 -0500
Subject: Re: 4 Re: [DCHAS-L] MSDS for obsolete chemical
All, I found this exchange particularly interesting. And one of Bruce's
sentences stood out:
"Now we are simply going to dumb them down (MSDSs to SDSs), to simple risk
phrases that will provide employees with pictograms, but leave us and
physicians in the dark."
While you hear a lot about the risk phrases, you probably should google the
"GHS SDS Purple Book" and read all the stuff that is supposed to be in the
new SDSs. Only a few big chemical suppliers in the US are actually doing
this right, so I see a lot of documents out there that say they are SDSs when
they are not.
If the purple book rules are followed, you will probably find section 10 on
toxicology the most interesting. There are 10 blanks for assorted acute
and chronic tests. The blanks can either contain the results of those tests
or the phrase "no data available." You can't use the misleading statements
seen on US MSDSs such as "not hazardous if used as directed," "not listed as
a carcinogen by IARC, NTP or OSHA" (which means it has never been tested),
"certified by a nationally recognized toxicologist as containing no hazardous
amounts of toxic substances," and on and on.
If manufacturers will actually follow the rules you should be able to look
at section 10 and find out not only what is known, but more importantly WHAT
IS NOT KNOWN. And under the EU precautionary principle, this means you
can't assume a chemical is safe unless there is data.
The precautionary phrases are for the shippers and handlers to make fast
decisions about exposure and clean up. The SDS itself should provide far more
information than the MSDSs and in a form that will enable us to provide
informed advice to users.
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