From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Original source of safety data?
Date: Thu, 26 Feb 2015 19:26:53 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 14bc86dcab7-43c5-7018**At_Symbol_Here**
In-Reply-To <0784F6E6-5503-4FF7-ABC7-CEDA75432730**At_Symbol_Here**>

It's a mess, Ralph.  I'm going to answer in a round-about way. 
In December a petition on behalf of the trade associations for the major chemical industries asked for and received from OSHA an exemption from the June 1, 2015 deadline for SDSs.  This includes the National Association of Chemical Distributors, the National Association of Manufacturers and the Society of Chemical Manufacturers and Affiliates.
Their rationale was amazing.  They said they couldn't comply because their primary sources were not providing the data needed on the SDS.   And that this "Often this involves a supply chain that is three to five layers deep."
And all along I thought they were withholding information.  Hell, they are claiming they don't KNOW. 
The other flaw in their logic is that they are assuming that the primary manufacturers have and test data or information to pass down to them.  Usually the physical and toxicological data on a chemical has to be obtained from various sources and studies done over the years.  Simply knowing the identity of the chemical should be enough to do a literature search.  But clearly, they are claiming they can only get the data from their suppliers.  And just as clearly, when they get that data they will copy it on to their SDSs. 
So that's my answer.  But as an aside:  the petitioners also included the adhesives and sealant makers, cleaning and disinfecting product manufacturers, composite makers, agricultural product makers, and even the Greenies got into the act through the Responsible Industry for a Sound Environment.
 I also have a question for all of these industries.  It is this:  Do you really think the other 162 countries that have adopted the SDS and are requiring it by June 1, 2015 are going to also give them a pass?   I hope they don't.  So those manufacturers who export would be wise to find a way to cobble together an SDS.
Sadly, you and I, who live and purchase chemicals in THIS country, we won't be getting a lot of good SDSs.  The reason is that OSHA extended this relief from the deadline to ANY manufacturer who can show they have made a good faith effort to obtain the information from their suppliers. And from what I learned to day from an OSHA Labor Liaison and an OSHA Senior IH, they will only be enforcing the requirement to show this good faith effort if you and I file a written complaint about the bad MSDS or SDS data.  Like that's going to happen.
So expect that MSDSs will be around in the US for quite a while.
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: Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Sent: Thu, Feb 26, 2015 4:20 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

- Ralph

Ralph Stuart, CIH, CCHO
Chemical Hygiene
Keene State College


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