The ingredients that appear in section 3 of an sds are those that have hazards. If the ingredients in the composition are not classified with a hazard according to the OSHA Hazcom 2012 guidance, they do not have to be listed. As for the label, it may have been prepared by a different guidance, such as CPSC, if it is a consumer product.
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Can you provide the Manufacturer, product name and part number?
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:
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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