As a longtime SDS Author and former Product Safety Steward, when approaching hazard communication for new chemicals I generally write about what I don’t know about the chemical instead of the typical approach of writing about what you do know about the chemical. That said, I will use data from structurally related analogs when writing about what we can logically predict about the unknown chemical with respect to its toxicological properties, ecotoxicological properties, reactivity and physical properties.
There are liability issues with providing a SDS that contains inaccurate information but the hazard communication standard is not specific with respect to exactly what those are as there are a variety of factors that determine the repercussions in the courtroom. A lawyer is best to consult in this instance. There is a difference between an inaccurate document being authored through willful omission or intentional misrepresentation versus ignorance. The HCS is based on the hazard identification and dissemination of that information based on “available” information on chemicals. When determining hazard for a new chemical for which very little information is available, in my opinion, you run the risk of inaccuracy by ignorance category. That said, it does not absolve one from performing due diligence in mining data for analogs and applying bridging principles to projecting hazards in use as well as downstream usage.
Regarding a researcher preparing the SDS, in my opinion, I feel they are ill equipped to understand the complexity of SDS authoring unless they have been trained in the classification schema for HCS 2012 and transportation classification. One of the primary reasons for there being so many “bad” SDSs floating around out there is due to the fact that there is a wide range of education in SDS preparation amongst authors in general. There is a vast difference between someone making a hazard determination who has been dedicated to the preparation of accurate SDSs and labels and someone who knows some things about its behavior while researching and synthesizing it in the laboratory.
I wholeheartedly agree with Mr. Buczynski that SCHC is a great resource for GHS training. However, they only offer training at their meetings which take place in the Fall and Spring each year. An additional training resource I use is ChemAdvisor who also offers extensive hazard communication training year round. Both resources allow you to select courses based on the country you are authoring for, which is critical, as every competent authority globally has approached the adoption of GHS using the building block approach and some countries have chosen to exclude some categories and some have chosen to adopt new ones in addition to the existing ones, such as combustible dusts in the US HCS 2012 standard or water activated toxicants in the Canadian WHMIS 2015 standard.
I also agree with Rob in that transport training is additionally necessary as the US DOT Hazardous Materials Regulations state that anyone offering for transport a hazardous material shall be trained, tested and certified and have a refresher every three years. If you are shipping to institutions outside of the US you should also have training, testing and certification in ICAO and IMDG regulations for air and water shipping classification and requirements as well.
I hope this is helpful!
Authoring Services Team Lead, MSDSonline
ACS, Chicago Chapter, Secretary 2015 & 2016
SCHC member since 1999
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu]
On Behalf Of James Stubbs
Sent: Friday, December 11, 2015 8:59 AM
Subject: [DCHAS-L] SDS Preparation for New and Novel Chemicals Created in Research Labs
I work for a large research university and we, like many of you, have researchers on our campus that create new and novel chemicals from time to time and then need to ship them to colleagues across the country. My questions deal with the SDS preparation for these new and novel materials: What is the comfort level with a self (researcher)-prepared SDS when we offer these materials for shipments? What is the comfort level with a researcher preparing an SDS which then becomes a safety guidance document for others using the material? What roles does the safety professional play in this process for your company/institution? Are there any liabilities to the institution if the SDS contains inaccurate information?
I have my own opinions but am hoping to tap into the collective wisdom of this group to get a broader perspective.
Many thanks in advance!
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