My experience evaluating MSDSs supplied by manufacturers over the years has been extremely varied to say the best. What qualifications were required to publish a MSDS, especially after legal disclaimers were applied?
Ralph - you’re on point here, maybe more than you realize. Consider how many glove or PPE guidelines have been "developed" by distributors vs. manufacturers, is it a copy, of a copy, of a copy OR the results of actual permeation and degradation testing results provided by a manufacturer? Ansell (note I am not a representative, salesman, no financial gain, etc.) has been performing actual permeation, degradation and breakthrough testing on their gloves for decades, see http://www.ansellpro.com/specware/. Over the years I have relied upon Ansell, SAX, Chris, etc., governmental guidance, which leads me to my question.
Is anyone else developing SDSs to comply with OSHA GHS SDS requirements found that we are relying more upon EU criteria, e.g., REACH, to meet those determinations more than U.S. sources?
Another question to answer is what U.S. resources are you relying upon? Hypothesis - if you are relying upon manufacturer's data only, could you be culpable in the long term? Conversely, will the legal disclaimer of a non-testing distributor absolve you of professional responsibility? Regarding the overall assessment, are you willing to rely upon the U.S.'s consolidated resources, e.g., the various Toxnet databases, or are you willing to rely upon a manufacturer’s assessment only? (I must note that although Toxnet is comprehensive, it is not user friendly. Toxnet is a compilation of multiple databases, which will only tell you which database your compound of interest is entered in, it is up to the user to investigate and determine if evaluating an LD50, LC50, teratogen, carcinogen or mutagen and their respective impacts.
Ralph - I think you are asking the right questions, but are they in the right order?
I think that first you have to accurate information regarding the chemical, physical or biological hazards involved to analyze which is the most important hazard and only then, can they be prioritized. The best analogy that I can think of at this point, comes from one of my initial computer classes involving bits and bytes which resulted in garbage in = garbage out. I think we need to focus on the quality of the inputs to make a categorization of the risks created by the hazards to characterize and prioritize those hazards that are the most significant. To answer the question directly "how critical is the accuracy of the information collected to answer the questions adequately"? Is the accuracy of the collected information =B1 50%, 20% or 10%? Which standards incorporated variations in sample analysis, =B125% (from memory) to be valid? Considering today’s technology who would consider =B125% to be acceptable? Possibly from the IH standpoint, are we meeting the 95th percentile, or 99th? What are we considering acceptable, under what standard? I learned one thing this past week which directly relates to answering the last question of “am I missing something here?” I discovered this past week while developing SDSs for new compounds that one of the most important criteria is to cite/document your sources for each element of the SDS. Please note, this was never a requirement under the old HCS and not now.. But what I have learned is to trust the source, based upon its credibility, sources with a high level of peer review or credibility or over a copy of a copy of a copy while documenting your sources! (It takes too long to backtrack! I am not seeking to disagree with your comments/questions, only follow-up.)
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Ray Cook
Sent: Wednesday, January 20, 2016 10:05 AM
Subject: Re: [DCHAS-L] HS teacher request info
Relying on a single SDS opens you to possible erroneous data & bad decisions. Response to hazmat since the 80s has always followed this advice, even though many other sources of info are available. (CHRIS, Sax, etc.)
Ray Cook, CIH, CSP
I Cor 1:18
Sent from my iPhone
On Jan 20, 2016, at 8:57 AM, Ralph Stuart <rstuartcih**At_Symbol_Here**ME.COM> wrote:
>> perusing various SDS (from different vendors) for the chemicals is always best!
> A philosophical question:
> I see the advice above a fair amount in the general chemistry literature (particularly J Chem Ed articles) and am never sure how random browsing of SDS's adds safety value.
> In my opinion, before reading SDS's, it's important to formulate the question(s) to be answered. Examples of such questions could be:
> - Which is the most important hazard involved in this work?
> - What other hazards impact the precautions to be implemented?
> - How critical is the accuracy of the information I'm collecting to answer these questions adequately?
> Am I missing something here?
> - Ralph
> Ralph Stuart, CIH
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