From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] U.S. & Canadian SDS query
Date: Fri, 15 Aug 2014 11:07:48 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 8D186B1CF5D83E8-1E6C-131F6**At_Symbol_Here**

Oh how interesting.  Basically, you have to meet each country's rules.  Both have set minimum requirements but do not prohibit additional information as long as it doesn't violate some information format rule. For example, I'm more familiar with the EU requirements which specifically wants the words "no data available" instead of US and Canadian alternatives like "none determined," "None Established," "not available," or the good old US trick of  listing only acute data and ignoring the existence of chronic hazards.  
The one that really burns my cork is "not listed as a carcinogen by IARC, NPT or OSHA"  which should be translated to mean "no data available."  People still believe chemicals are tested before they are marketed.  Statements like this only encourage this wishful thinking.
This problem may not be as acute when you are ordering from international sources like Aldrich, but it sure is with the consumer, construction, and small business SDSs I have to deal with.  They are just doing business as usual.  What new laws?
Since the GHS rules say we can provide more information than required, the bottom line is you can paste, but not cut to get the new combo version.
And it also means that smart people who really want to know what is known and what is NOT known will take the name and CAS # off that US/Canadian SDSs and google-up an EU version for the same chemical.  Sad.
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

-----Original Message-----
From: George_McCallion <George_McCallion**At_Symbol_Here**VWR.COM>
Sent: Fri, Aug 15, 2014 10:23 am
Subject: [DCHAS-L] U.S. & Canadian SDS query

Dear DCHAS members,

I am currently working on creating a GHS-compliant SDS that is a hybrid of both the U.S. and Canadian versions.

Has anyone made an attempt at this? I am finding out that merely cutting & pasting one into the other is not going to work.

Thank you in advance for any feedback possible.

George D. McCallion

George D. McCallion
Regulatory Affairs Specialist
VWR International, LLC
Radnor Corporate Center, Building One
Suite 200, P.O.Box 6660
100 Matsonford Road
Radnor, PA 19087
Office: 610.386.1449
Email: george.mccallion**At_Symbol_Here**

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