Well, I'm going to rain on this parade. The quote from hazcom below about SDSs on nonhazardous products is why I'm having such a hard time getting SDSs on art materials. Manufacturers say they don't need them because their stuff is nontoxic.
There colors are labeled nontoxic because the rule under which they label, ASTM D 4236, only requires warnings on KNONW chronically hazardous materials. Most organic pigments are labeled "nontoxic" because they have never been tested for chronic toxicity. Even pigments in classes we know will cause cancer if they are ever tested are labeled nontoxic. And the inorganics are tested for solubility and considered safe if they are insoluble. Yesterday I saw both the old MSDS and the new SDS on cadmium pigments from a major manufacturer that asserts that these cadmium compounds are insoluble so they are not not toxic.
(And for you toxic waste wonks, there was nothing on either the MSDS or the SDS to alert you to the issues with disposal of paints that may contain from 40 to 60% cadmium by weight and in a nanoparticle size that will present a really large surface area to the TCLP acids.)
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I've heard that solubility tune before. ACMI used an acid test to predict bioavailablity of lead glazes and for decades they were labeling lead glazes "nontoxic" and/or "lead-free" until someone damn died in 1992 and in 1997 two big lawsuits were settled by ceramic manufacturers that were brought on behalf of children allegedly damaged in utero because their moms believed those labels and did ceramics while they were pregnant. I handed that ACMI toxicologist a 1985 study at a meeting in January of 1989 which showed that two major insoluble lead frits bioavailable by both ingestion and inhalation in animals. He chose to ignore that evidence. I have published sections of the toxicologist's 1997 depositions where he admitted that he was wrong in thinking that the acid solubility of lead frits was a predictor of bioavailablity.
That did not stop the toxicologists for ACMI from continuing to use solubility tests to predict bioavailability of other pigments, both inorganic and organic. Without animal testing, you just don't damn know what mechanisms may function to absorb those chemicals. People are not simulated gastric juices. There are vast numbers and types of bacteria in the gut, cellular mechanisms in all the many types of cells encountered on that 30 foot trip from in to out, and metabolic pathways as yet unknown.
So don't throw away the SDSs on art materials that tell you the products are nontoxic. The chemicals in these products are either untested for chronic toxicity or determined to be nontoxic under ridiculous procedures that I can't get the ASTM committee to understand should not be used to label products "nontoxic."
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: Melissa Charlton-Smith <melissafcsmith**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Sat, Sep 24, 2016 6:30 am
Subject: Re: [DCHAS-L] A Conundrum
LOL, ok I am jumping on the band wagon, and here is a link to questions regarding the HazCom standard:
and here is a copy/paste of why I think OSHA doesn't require an SDS for water....it's not hazardous (though it can participate in hazardous reactions, it in itself is not considered hazardous). Of course if you look at the dates on this, you will note it is PRE-GHS
Is a material safety data sheet (MSDS) required for a non-hazardous chemical?
MSDSs that represent non-hazardous chemicals are not covered by the HCS. Paragraph 29 CFR 1910.1200(g)(8) of the standard requires that "the employer shall maintain in the workplace copies of the required MSDSs for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their workarea(s)." OSHA does not require nor encourage employers to maintain MSDSs for non-hazardous chemicals. Consequently, an employer is free to discard MSDSs for non-hazardous chemicals.
Reference Interpretation and Compliance Letters:
Mel Charlton-Smith
Certified CHO
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On Fri, Sep 23, 2016 at 2:31 PM, David Roberts <droberts**At_Symbol_Here**depauw.edu> wrote:
To put it differently, why would they make us have one for sodium chloride or calcium carbonate (which is in our water at high levels actually) but not for water. Our water here is so high in calcium carbonate it's crazy - I could probably get enough for general labs just by boiling down regular tap water - though that of course would not be cost productive I know.
And I do know the reason. I was just stirring the pot.
It's Fryday ;)
Dave
> On Sep 23, 2016, at 2:01 PM, Ben Ruekberg <bruekberg**At_Symbol_Here**CHM.URI.EDU> wrote:
>
> My curiosity will not allow me to wait until April first, when it might be more excusable, to ask this question.
>
> There is a chemical which can be found in almost every laboratory. Most laboratories even have it piped in. There are (M)SDSs for this material and yet, while I am told that we are required to have the (M)SDS for each of the chemicals in our laboratory on hand, I don't believe that many laboratories keep a copy of the (M)SDS for this substance in print. I refer, of course, to water.
>
> OK, I hear you saying "Of course no one has the (M)SDS for water on hand. It's water." And I agree: I mean it's in the safety showers, we wash our hands with it before leaving the lab. But it's a chemical. I can understand why I would make an exception for it, but does OSHA?
>
> Can anyone tell me why safety documentation is not required for water? Or is it? Or is it, but no one makes a fuss about it?
>
> Thank you very much,
>
> Ben
>
> Virus-free. www.avast.com
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