From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] GHS labels for food stuffs used in labs
Date: Wed, 17 Jun 2015 17:18:15 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 14e0362fbe5-543d-2498**At_Symbol_Here**
In-Reply-To <008201d0a933$64fd6a20$2ef83e60$**At_Symbol_Here**>

Well, I don't have time for the FDA issue, But I sure can find the answer fast for the cosmetic issues since I train theater hair and make up works and now am involve in the flap over nail salons:

In a 1994 federal register notice from OSHA clarifying some of the hazcom rules (59 FR No. 27, Wed. February 9, 1994, p.6150) there was the following comment (quote):

Cosmetics.  OSHA has separated the exemptions applying to cosmetics and placed them in a new subparagraph, but has not changed the substance of the requirements.  Cosmetics are exempt when packaged for sale to consumers in a retail establishment, and when brought into the workplace for employee consumption.  Otherwise, they are covered by the rule when they contain hazardous chemicals.

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 Walton <georgewalton**At_Symbol_Here**REACTIVES.COM>
Sent: Wed, Jun 17, 2015 4:45 pm
Subject: Re: [DCHAS-L] GHS labels for food stuffs used in labs

I imagine there will be a lot of responses to this..  One reading of 29 CFR 1910.1200 (b)(5) [This section does not require labeling of the following chemicals. . .] is that (1) FIFRA-regulated pesticides, (2) TSCA-regulated substances or mixtures, (3) food, food additive, etc , medical or veterinary device or product . . .Federal Food, Drug, and Cosmetic Act or Virus-Serum-Toxin Act . . .  Food and Drug Administration or the Department of Agriculture, [and more] is that all those items described in (b)(5) (i) through (b)(5)(vi) do not require labeling.  However, if WI is an agreement state, it can promulgate additional regulations in the absence of a federal standard.
First, check with the "OSHA" department in Wisconsin (Labor and Industry; Labor; etc.)  - have they published an addendum to or expanded 1910.1200?
Second, protect people.  (Easier said than done.)
Third, look at the materials listed in 1910.1200 (b)(6) [This section does not apply to: . . . ]  Again, there may be an addition under WI standards that would require labeling.
Fourth, are these "hazardous chemicals" under the lab standard (1910.1450)?
All the above may be wrong but if you recognize the hazard and protect people from them, then you are doing rather well.
George C. Walton, CHMM
Reactives Management Corporation
1025 Executive Blvd., Suite 101
Chesapeake, VA  23320
(757) 436-1033
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of Osterby, Meg
Sent: Wednesday, June 17, 2015 1:37 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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