Don't repeal it - it is a cash cow for consultants. The definition of who qualifies effectively insures the individual against E&O claims; love it.
However, I got out of certifying when the "certification farms" came into existence. Michael's, Art Barn, etc love those companies and certainly keep them in business!
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ACSafety has a new address:
NEAL LANGERMAN, Ph.D.
ADVANCED CHEMICAL SAFETY, Inc.
PO Box 152329
SAN DIEGO CA 92195
011(619) 990-4908 (phone, 24/7)
We no longer support FAX.
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From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: Wednesday, November 19, 2014 12:58 PM
Subject: Re: [DCHAS-L] GHS query-markers
Oh dang. I was one of the idiot activists that helped to get ASTM D-4236 into the Federal Hazardous Substances Act for art materials. And I have now called for it's repeal. It is worse than nothing they way it has been interpreted by the toxicologists who are paid either directly or indirectly by the manufacturers to certify products as nontoxic or safe.
Anyone interested in why they should NEVER believe an art material label can contact me off the forum and I'll pdf detailed information about this dumb law.
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: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Wed, Nov 19, 2014 3:40 pm
Subject: Re: [DCHAS-L] GHS query-markers
From the MSDS:
"NewellRubbermaid, Inc (Sanford L.P.) is a member of The Art and Creative Materials Institute, Inc. This product is certified by the Institute to
be labeled in accordance with the voluntary chronic hazard labeling standard ASTM D-4236 and is labeled with the AP Non Toxic Seal.
Products bearing the AP Approved Product Seal of The Art and Creative Materials Institute, Inc. are certified in a program of toxicological
evaluation by a medical expert, subject to review by the Institute Toxicology Advisory Board, to contain no materials in sufficient quantities to be
toxic or injurious to humans, or to cause acute toxicity or chronic health problems [bold my emphasis]."
So would that put it in the category of "non-hazardous" and not fall under the guidelines:
From Jeff Tenny's quote:
"Employees who are required to work with hazardous chemicals [Bold, my emphasis] in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the properties of those hazardous chemicals."
The original MSDS:
On Wed, Nov 19, 2014 at 2:50 PM, Jeff Tenney <Jeff.Tenney**At_Symbol_Here**sdmyers.com> wrote:
Depends on use. Under Hazcom:
Do you need to keep MSDSs for commercial products such as "Windex" and "White-Out"?
OSHA does not require that MSDSs be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. This exemption in OSHA's regulation is based, however, not upon the chemical manufacturer's intended use of his product, but upon how it actually is used in the workplace. Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the properties of those hazardous chemicals.
Reference Interpretation and Compliance Letters:
=E2- Provision of MSDSs for consumer products used in the workplace. [1/9/90]
=E2- Applicability of the HCS to office workers and copy machine operators. [3/31/89]
=E2- Application of the HCS MSDS requirements to distributors selling hazardous chemicals to consumers and employers. [5/16/90]
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of George D. McCallion
Sent: Wednesday, November 19, 2014 2:12 PM
Subject: [DCHAS-L] GHS query-markers
Dear DCHAS Staff,
Would any members know if, in fact, that markers (i.e., Sharpies) are classified under the GHS system?
If yes/no, can a reference be provided?
Thank you in advance.
George D. McCallion
124 Magnolia Court
Collegeville, PA 19426
"If you fail to plan, then you plan to fail"
Departmental Laboratory Supervisor
Michigan Technological University
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