I'll look into this when I get a minute. I think there are still some sites that compare what is required on U.S. SDSs and what is required by the E.U. I know OSHA didn't require a number of things for U.S. SDSs. However, don't try exporting with a U.S. SDS since about 162 countries signed on to the U.N. and/or more recent E.U. versions. That's why you don't have to indicate which of the 10 toxicity tests have been done and which haven't for a U.S. SDS in Section 11 -- which I bitched about yesterday.
And we still require statements that are considered misleading under E.U. rules such as "not listed as a carcinogen by IARC, NTP and OSHA" which, of course means these agencies have not evaluated the chemical for carcinogenicity usually because there is "no data" or almost no data. Why not just damn say that?
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If you want to see pretty good E.U./U.S.-compliant ones, most SDSs from Sigma Aldrich are exemplary. They still have the U.S. cancer statement, but they are damn good. If S-A was a nonprofit, I'd donate.
And when you look at OSHA's hazcom rule for SDSs, note that in the appendix OSHA recommends providing more and better data than what is required. So why not get all that good stuff on there? I so wish the U.S. was doing the best job on SDSs in the world instead looking for ways to provide less data and say things in ways that people are likely to misinterpret.
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: Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Dec 8, 2016 9:40 am
Subject: [DCHAS-L] GHS Hazard Statement codes
Someone asked me the other day if the Hazard Statement codes (H220, etc.) are part of OSHA's HazComm standard. As far as I can tell, they aren't and US SDS's don't include them. Am I correct in this? Anyway know why they might not be included in the US?
Thanks for any help with this question.
- Ralph
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
ralph.stuart**At_Symbol_Here**keene.edu
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