Your response was dead on. Can I quote you (with credit of course)?
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: Friday, July 12, 2013 9:13 AM
Subject: Re: [DCHAS-L] Devarda's Alloy
Well, when you set up the soap box and turn on my violet key light, I just gotta start my shpiel. I ask you to read even the first line of Jeff's comments again. There's the actual reason why I am so disappointed in OSHA's messing up the intent of the UN's GHS SDS with their bastardized OSHA version, especially of Section 11 on toxicology. All of Jeff's confusion would be easily dealt with by the UN's Purple Book version of the SDS as accepted by many EU and other countries. This UN version requires 10 blanks representing 10 different toxicological tests, which then establishes for you whether you are looking at the results of ingestion, inhalation or skin contact. The UN SDS requires either the data from that test in the blank or the words "no data available." Then the additional information about routes of entry, symptoms and so on are to be covered and their is a distinct prohibition against the squishy kind of language that is so confusing.
Here's one of the provisions from the GHS Purple Book, Annex 4 on SDSs:
A184.108.40.206 General statements such as "Toxic" with no supporting data or "Safe if properly used" are
not acceptable as they may be misleading and do not provide a description of health effects. Phrases such as
"not applicable", "not relevant", or leaving blank spaces in the health effects section can lead to confusion
and misunderstanding and should not be used. For health effects where information is not available, this
should be clearly stated. Health effects should be described accurately and relevant distinctions made. For
example, allergic contact dermatitis and irritant contact dermatitis should be distinguished from each other.
And it goes on and on from there. All of the warning phrases are proscribed word-for-word.
And that's just the toxicology data. There are similar requirements for the physical properties.
But you and I, friends, are going to continue to see MSDSs and OSHA SDSs that are just manufacturers' promotional spins on toxicology. You will continue seeing "not listed as a carcinogen by IARC, NTP & OSHA" which really means: "no data available." And "nontoxic" when the product is actually highly toxic but exposure should be within tolerances "when used as directed." As the title of the book written by my friend David Michael (OSHA Director) explains: "Doubt is their Product." And he shows how well this doubt and confusion works for them.
Yesterday, I did an interview for German Radio on the implications of REACH in the current US/EU Free Trade Negotiations. And this issue and the phony US consumer labels which will NOT change with respect to GHS came up. I know damn well, that if I were pitching a WNYC program (I'm a regular there) this subject would be "too deep" and the Producers would have to reject it. How sad for us all.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
From: Jeff Tenney <Jeff.Tenney**At_Symbol_Here**SDMYERS.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Thu, Jul 11, 2013 9:50 pm
Subject: Re: [DCHAS-L] Devarda's Alloy
There is good reason why these very so widely.
Health rating: What is the likelihood of it being ingested? If I think the product could be ingested or inhaled (fine powder) and am writing the MSDS I would give it a higher Health number. If it was something larger or even a rod/sheet then I would give it a low health number.
Fire rating: Again fire rating will vary as to how easily the material will ignite. A powder may need to be classified as a flammable solid 4.1 while larger size pieces would not be considered flammable at all.
Reactivity rating: Again the powder form would generate a higher number. Aluminum powder is classed by DOT as a 4.1 or 4.3 depending on whether it is coated or uncoated. (50% of the mixture) It also can be water reactive.
Some people who write MSDS's are more conservative than others. You will always have to default to the manufactures MSDS but there is nothing that keeps you from going above and beyond what the manufacturer recommends. We experience the same problems with gloves. When we get conflicting information we will investigate and side on the side of safety.
If it was me I would store the material in the flammable cabinet, no matter what the MSDS reads, just as a precautionary measure. I would have it in a secondary container as well so if it does spill it would be easier to clean up. I would not want someone to think it was safe to have this product around an open flame, water or acids or have the ability to spill the product and create an airborne dust. We find that by storing material in a hazard cabinet adds to the person awareness when it comes to handling the chemical. People use a little extra care when hazards are reinforced by a large yellow cabinet.
Just my opinion,
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Emily Coombs
Sent: Thursday, July 11, 2013 1:03 PM
Subject: [DCHAS-L] Devarda's Alloy
We recently acquired some Dacarda's Alloy and are being faced with whether or not it needs to be stored in a flammables cabinet. We have not yet received an MSDS from the Manufacturer, and even just the NFPA ratings seem to vary incredibly. (Yes we are absolutely looking at the rest of the MSDS, but this provides a quick overview of how differently it is being presented in the different sources.)
From Sigma Aldrich (available from their site, but I am unable to attach here):
Health hazard: 0
Reactivity Hazard: 3
From ScienceLab MSDS
From SIRI (not a source I would normally use, but is specifically listing the brand we have)
Health Rating: 0 - None
Flammability Rating: 1 - Slight
Reactivity Rating: 1 - Slight
Contact Rating: 0 - None
Can anyone shed any light on this particular materials' storage? It has caused some controversy here, and we would appreciate another perspective. Thank you!
Chemical Laboratory Manager
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