From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] GHS labels for food stuffs used in labs
Date: Wed, 17 Jun 2015 14:33:29 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 14e02cc235d-4dbe-1b38**At_Symbol_Here**
In-Reply-To <58C74A3BBE6D644C8538C5848AC53025D4E86969**At_Symbol_Here**>

Meg,  Just wrote two reports on UW campuses so I'm up on your regs. And as I see it, your consultant is basically right.

In the new GHS Hazcom, the labeling approved by the US CPSC and the US FDA are acceptable, so you don't have to pictograms on any container of food that is from the manufacturer.  But if you put the food in a secondary container that is unlabeled, then you have to do the labeling. 

And the SDS on the non-food products are not your problem.  It's the problem of the people selling you this stuff and your school's hazom program.  Your school already should have old MSDSs on file for them all.  Whenever a consumer product is used in a workplace, especially if it is used in amounts greater, or in ways other than, an ordinary consumer would use them, they are under your hazcom or lab standard program.  So contact the manufacturers and ask for their SDSs.  They know that they need to provide them to commercial customers. 

They might only send an updated MSDS.  The fed OSHA gave a two-year stay on SDSs to all US manufacturers who can show evidence that the information they need to fill out the SDS is not being provided by their primary ingredient manufacturers.  But they need to "prove" this case by case with e-mails, letters, etc.

For the food products that are not being used for food, I don't think you need an SDS, but you could do a simple written risk assessment for the proposed experimental use to meet the intent of the law.  And your rationale is the same as that for manufacturers:  You can't get all the information you need because it, like, mostly doesn't exist?   

Or you could get a blank SDS and just file almost all the blanks with "no data available."

Anyhow, that's how I see this.  

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: Osterby, Meg <OsterbyM**At_Symbol_Here**WESTERNTC.EDU>
Sent: Wed, Jun 17, 2015 1:39 pm
Subject: [DCHAS-L] GHS labels for food stuffs used in labs

Hello all,
Our safety consultant has been told that in the State of WI, one needs to have SDS sheets and GHS labels for household products, whether food or not, that are used in chemical experiments.  I=E2=80™m hoping she's wrong, since we analyze cattle feeds (soy, corn, alfalfa, and mixed grains) for our agribusiness students, hotdogs for our bioorganic students, as well as egg white, milk, etc. also for them, and a whole slew of foods, cleaners, and personal hygiene products, which we measure the pH of, for our general chemistry courses.  According to the consultant, if we are using a product for other than its intended use, in a lab, we have to have it properly labelled, and have to have SDS's. 
I am aware that most colleges and universities in the US are exempt from many of the OSHA, and GHS provisions, but here in WI, the technical college system is governed by the DPI, ultimately, and their documents pertaining to these issues, state that all schools in WI, under the DPI, must follow federal OSHA and other chemical regulatory bodies rules.  So, while my husband works at a State 4 year University, and has to do none of this, I'm at a Technical College, and have to.
I'm working on it this year, because the College is undergoing some renovations, that will make it impossible to do next year.
So, my question is this: If I'm supposed to properly label according to GHS, and have SDS sheets for everything I use in labs, how do I get them?  I'm fairly sure you can't look up an SDS or MSDS for Oscar Meyer beef franks, for instance, or for Gillette Men's Gel Deodorant, or for 7-Up, so what do I do?  Do I just make (relatively useless) labels saying they are harmless?  If so, then what about measuring the pH of Cascade liquid, or The Works Toilet Bowl Cleaner?  That's proprietary, and they're not going to want to give me the SDS, right? And yet, the Cascade is pH higher than 14, and the Works less than 0.   And while soda pop (Pepsi, Mountain Dew, 7-Up) can ruin a car finish, they are generally considered harmless.
I am definitely getting the idea of why this isn't done by most states for their schools.   This is really a difficult project I'm trying to get done.
Any helpful info the list can give me, would be appreciated.  It is okay to respond to me directly.
Thanks much,
Meg Osterby
Lead Chemistry Instructor
Western Technical College
400 7th St. N.
LaCrosse, WI 54601
"It's  better to be careful 100 times, than to be killed once." 
                                                    Mark Twain

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