From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
Subject: Re: [DCHAS-L] SDS missing ingredients
Date: Fri, 23 Feb 2018 16:04:40 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 96B01B2E9C84674ABE1BA48CDA3391030336108AD1**At_Symbol_Here**BPMAIL.bpi.local

If the manufacturer of the product doesn't deem something hazardous, then they don't have to put it on the label or the SDS*.  (*There are exceptions based on usage and claims, such as cosmetics and biocides.)  Have you ever looked at a motor oil label or SDS?  One might think they only contain base oil, though in reality they typically contain detergents (calcium soaps), dispersants (PIBSAs), antioxidants (phenolic and aminic), ZDDP (zinc), glycerol monooleate (OFM/slip), and other goodies—all in excess of 1% to the tune of at least 15% in total. 


The label and SDS (section 3) you reference are likely completely compliant.  EPA requires the actives (the quats) be listed on the label, so they're satisfied.  CPSC isn't going to care about a small amount of Glycol Ether DB or EDTA, and the otherwise flammable propellants in those quantities are "so-whats" in a water-based formula because they won't flash in a wet mist.  CPSC should be satisfied (if they even have an ingredient labeling say on a product with kill claims).  The "missing ingredient" exceeding 1% on the SDS is just water, so OSHA should be happy. 


FWIW, if I were writing the label and SDS, I wouldn't have put water on either UNLESS I were specifically touting the fact that this is a water-based product for marketing reasons.  There are multiple federal fingers in the pies in question, so it can be confusing.  I myself suspect both label and SDS comply with the minimum federal labeling and ingredient disclosure requirements, and I probably would have authored them the same or similarly.


Best regards,


Dan Nowlan

Chemist, R&D

Berryman Products, Inc.

(817) 640-2376, ext. 147


From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Hadden, Susan [JRDUS]
Sent: Friday, February 23, 2018 8:55 AM
Subject: [DCHAS-L] SDS missing ingredients


While investigating an incident at my site recently, I came across an interesting issue. Interested in your thoughts.


The material involved is a commercially available spray disinfecting cleaner.


The container label listed these ingredients:

Active ingredients:

N-alkyl dimethyl benzyl ammonium chloride, 0.1%

N-alkyl dimethyl ethyl benzyl ammonium chloride, 0.1%

Inert ingredients:  98%


I pulled the SDS to look for more exposure information. The SDS (updated June 2017) did not list those active ingredients but did list the propellants used and EDTA.  

This is what the SDS says:


Chemical Name                                                CAS number       %

Butane                                                                 106-97-8               1-5

Diethylene glycol monobutyl ether            112-34-5               1-5

Propane                                                               74-98-6                 1-5

EDTA                                                                     64-02-8                 1-5


Composition comments                US GHS: The exact percentage (concentration) of composition has been withheld as a trade secret in accordance with paragraph (i) of 1910.1200.


I took that statement to mean the exact percentage of the ingredients listed were withheld, not that there were other ingredients not listed. It says percentage, not components. Though if you do the math, clearly something is missing from this list.


I thought that rather odd so I called tech support of the manufacturer. At first, they were confused as well, then told me that because the active ingredients were EPA registered materials, they did not have to be listed on the SDS. My reaction: Say what???


I have seen SDS that said proprietary mixture but still gave you a clue. But I had no idea an SDS could give no indication that there were other ingredients. 


No one I have asked at my organization has ever heard of this.


Have any of you? 



No longer trusting SDS (which I suppose I should know better than to anyway).


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