From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)
Date: Fri, 23 Nov 2018 21:43:11 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 3B25DDD5-5ECD-4434-8421-F80CF014F265**At_Symbol_Here**

> >A provocative question with many facets. Always good to stir the pot!
I should have specified that I was thinking of the laboratory use case with inventories of more than 50 chemicals in laboratory scale containers when I posed the question. I also don't think of regulatory compliance as value added to the use of the chemical, but rather an adjunct to the use of the chemical. Given that the average penalty associated with a HazCom violation is $500, which is less than the cost of many chemicals, I'm looking for ways that the safety information can be best used to support better use of the chemical.

> >Further, SDS‰??s are part of your training requirement (see the next FAQ answer in that link). Hard to train employees with information you don‰??t have in hand and that they can‰??t refer to.
I'm not sure that SDS's are for employees - they are written by chemical safety experts and significant safety expertise is needed to parse and interpret the information on the SDS. My hope is to help lab workers understand the GHS labels proficiently and then work with them to use SDSs to help answer specific questions that they have after reviewing the label information.

> > An Internet search, on the other hand, presents a barrier for several reasons - for example, if a manufacturer has gone out of business, it‰??s an esoteric or proprietary chemical etc. not to mention that many folks really don‰??t know how to search effectively.
There are many other barriers associated with an Internet search - cryptic search ranking mechanisms obscure valuable sites, web sites that hide information behind poorly named tabs, etc. However, I'm not sure acquisition of an SDS is the end goal of someone working with a chemical - I suspect that they want to be able to answer a question about the use of a chemical.

> >Might find a web page that says sodium chloride is a probably carcinogen because chlorine is found in carbon tetrachloride etc.
This is precisely why a significant amount of chemical safety expertise is need to use SDS's; I think that many safety people undersell their skills in dealing with these challenges when they suggest anyone working with a specific chemical should be able to deal with all of the safety information available for it.

> > A complete SDS has the manufacturer‰??s name and contact information along with other data that might be critical to, say, an emergency room physician.

I agree that many emergency responders ask for SDS's, but I don't think SDS are well suited as emergency planning documents.

As you said, since (M)SDS's have been around for 30+ years and the GHS for 5 years, I think it's time to consider whether their value are worth the investment or whether there are other approaches to supporting worker's right to know, right to understand and right to act.

Thanks to everyone for their comments on this. I'd be interested in what others think as well.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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