From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)
Date: Tue, 27 Nov 2018 17:04:45 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 1567782592.7604260.1543338285132**At_Symbol_Here**
In-Reply-To <1109037139E1524980CF9CBEB24766180118B6A7B4**At_Symbol_Here**>

Monique.  I love the new SDSs.  I find them very clear when they come from reliable companies that do the GHS categories and data reporting correctly.  And once students are taught what these documents should say, they can also determine when a company is unable or unwilling to provide the proper data in the proper format.  That's a red flag they should all be able to recognize.  So I usually train with at least one rotten SDS to make this point.

And remember, thank our U.S. OSHA's desire to make manufacturers happy for making the information on the 10 tests in Section 11 on Toxicity non-mandatory.  So I also tell users of individual chemicals with bad SDSs to get a data sheet on the same chemical sold either by a U.S. exporter of an E.U. exporter who usually do it right.  

And when something just doesn't add up on an SDS from good manufacturers, it is time to search the literature to find out why.  Recently, I was asked by a client who booked me for a GHS training to use an SDS on indigo dye as an example for the trainees.  But on every indigo SDS from good companies, I saw the same contradiction:  chronic STOT would be listed in Category 2 in Section 3 but the words "no data available" would appear on the chronic STOT line of Section 11.  Hmmmm.  Time to search.

And the reason is a pip.  The GHS Section 11's ten tests are standard toxicity tests. These chronic tests have never been done on indigo.   But cancer researcher are doing some really strange new tests.  One of these new tests looks for aryl hydrocarbon receptor (AhR) ligand function.  AhR-mediated signaling is required for xenobiotic ligands such as the dioxins or PCBs to be toxic.  Studies now show that indigo is as strong an AhR ligand as the most toxic of the dioxins (2378 TCDD).  And one of indigo's metabolites, indirubin, is 50 times stronger than 2378 TCDD.  

Corroborating evidence comes from the fact that indigo and its metabolites are found in the urine of patients with acute myelomonocytic leukemia and porphyria.

This is a wonderful lesson for our costume workers.  Even when there is no date or the data appears to indicate the chemical is not very toxic, It may be hazardous.  And this is true even for chemicals we have accepted as being used for hundreds of years and "natural."  Maybe now I can convince them it would be a good idea to glove-up and take precautions to avoid snorting the powdered indigo and other dyes during use.

 Does this mean that everyone of my trainees can to this kind of literature search and understand the results?   Clearly "no."  But part of the training is to be able to recognized an SDS that doesn't make sense and to call their Safety Officer to find out why.   And this connection to the trainee makes you an indispensable part of the worker safety programs -- which is the only legitimate form of job security.  

SDSs are not an impractical part of training you must do because you "have to."   They are a grand opportunity.


-----Original Message-----
From: Wilhelm, Monique <mwilhelm**At_Symbol_Here**UMFLINT.EDU>
Sent: Tue, Nov 27, 2018 10:05 am
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)

Unfortunately, yes they are necessary for legal reasons, not practical ones.  As an educator of safety, I teach people about SDSs only because I have to.  What they really need to understand is GHS.  I personally feel that SDSs are useless for the lab chemist because of (even with GHS) inconsistency and statements that are too broad.  But I also am sure to mention these downfalls of SDSs and discuss other ways of determining likely hazards of chemicals such as previous experience, chemical structure, reaction chemistry, and other resources such as Lange's, Bretherick's, and Sax's handbooks.  My actual go-to safety resource that I refer to anytime I don't recognize a chemical that has been requested is my old '92-'93 Aldrich catalog.  Even the 2012-14 version of that catalog has GHS codes that have been reliable for everything I have searched thus far.  So, for the little bit of what I get to them that they will actually keep with them, I prefer that they understand what th!
e GHS codes are telling them instead of interpretations of a combination of broad statements that will vary from one SDS to the next..  Why have the focus be on a huge document that sometimes confuses me? 2 cents...

Monique Wilhelm
Laboratory Manager
Department of Chemistry & Biochemistry
University of Michigan - Flint

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Stuart, Ralph
Sent: Friday, November 23, 2018 4:43 PM
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)

> >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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