The question is, after taking the course, would the students be able to do risk assessments?  And I contend that this depends on the knowledge they had when they sat down at the beginning of the course.  If they were already familiar with basic science concepts, then perhaps.  But if you have to start out with people who have no idea what a chemical is, you have no foundation to build on.  

I also feel that politics have to be part of these courses. Students need to know that most chemicals are unstudied for toxic effects, in particular chronic effects.  And the phrase required only on U.S. SDS: "Not listed as a carcinogen by IARC, NTP and OSHA" means that these agencies haven't evaluated the chemical for cancer effects because there is either no data or insufficient data.   And why the E.U. specifically does not allow these kinds of misleading statements on their SDSs, requiring instead the words "no data available."

And that the reason we suddenly have new SDSs and labeling is that the rest of the world signed on to the better system developed by the U.N and adopted first by the E.U. and then by 162 other countries   If we had not changed our SDSs and labels, we would not have been able to export to the E.U. after June 1, 2015.  The U.S. OSHA would NEVER have been able to improve anything without this E.U. requirement. 

Also make sure that students understand the difference between the U.S.. system of "chemicals are innocent until proven guilty" and the E.U.s Precautionary Principle.  This is crucial because your art, theater and architecture students will almost NEVER see the GHS label on ANYTHING they use. 

Instead, they will see CPSC labels on consumer products, FDA labels on cosmetics, and EPA labels on pesticides and disinfectants.  And these labels have words that are very different from each other and from GHS label terms in meaning.  So if you take the art people into your class, you need a module on the three other labels (CPSC, FDA and EPA). 

 And under the CPSCs special label rules for art materials (which requires compliance with ASTM D 4236 stated on every label), untested chemicals are routinely labeled "nontoxic."  In fact, untested pigments and dyes in chemical classes we KNOW will cause cancer in animals if tested are also labeled "nontoxic" under ASTM D 4236.

In some ways, chemistry students have it easy.  Their labels actually identify the chemicals in the bottle.  They don't have to wade through the maze of phony label terms, advertising, and trade secrets. 

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