In my line of work, I see a great deal of legacy data and much if not most of it is questionable at best, just plain incorrect at worst. A few of the things on my checklist when I am taking a legacy product and creating a GHS document are:
1) clarify whether the data points on the legacy document are for the actual product, for the most hazardous substance(s) in the mixture, or bridged from a similar product.
2) research the components of the mixture for the most current physical and health property information using reputable sources (ECHA registered substances, HSDB, RTECS, IUCLID, ICSC, NIOSH, EPA's Chemical Reactivity Worksheet, etc).
I tend to err on the side of caution and am inherently mistrustful of legacy document data. Regarding potential conflict, I generally have few problems conveying to the client that the data has changed and that there is more current data that is more appropriate to use for their product SDS. I also stress that the promulgation included that the data needs to be in accordance with OECD guidelines and antiquated data does not fit this criteria. I spend quite a bit of time investing in client education but it is well worth it. It goes without saying that if the client has paid for toxicology and/or ecotoxicology studies, physical property testing, etc it trumps any component data points and I will use it, provided the tests were carried out in accordance with OECD Guidelines. I always request the studies and laboratory analysis so I have the data to back up my document and I can prove it to be scientifically defensible.
I try not to use legacy phrasing as well unless it is specific to the product or its downstream usage. Sticking to the GHS hazard and precautionary statements for content and verbiage is best in my humble opinion.
Great question! I am interested in hearing what others encounter!
Authoring Team Lead
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Stuart, Ralph
Sent: Thursday, February 26, 2015 3:19 PM
Subject: [DCHAS-L] Original source of safety data?
During our ongoing project with CINF in identifying sources of electronic chemical safety information, a set of questions that has arisen:
- What is the original source of most chemical safety information (e.g. flashpoints, health hazard data, reactivities, etc.)? - How much information, for example on a SDS, is simply copied over from another source and how much data is actually generated and/or verified by the author/publisher of the source?
- What is the original source of this data?
- How are potential conflicts in this data between these information sources resolved?
I'm sure there are people on DCHAS-L who have experience in answering these questions for professional safety purposes; any comments on any or all of these questions would be appreciated.
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
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