Amen! Your answer was almost perfect. But I would like to modify "NEVER assume any chemical has had ANY test until you see the results of that test on the SDS." To -seeing the results of the tests on any peer-reviewed or U.S.A. Government resources such as TOXNET. I've seen a lot of SDSs that didn't include the latest Tox testing results which would have modified their classifications - but the information was available.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Monona Rossol
Sent: Friday, April 26, 2019 10:38 AM
Subject: Re: [DCHAS-L] MilliporeSigma Introduces New Greener Solvent, Cyrene=E2=84=A2
You asked, "Can a "Greener Chemical" have a "no data available" section on it's SDS?
That is, shouldn't a complete hazard assessment be required before such a claim is made? It seems to me that a SDS provides the outline of the various aspects of a chemical's hazards that should be systematically investigated before such a conclusion is reached..."
The answer to that questions is my objective in my GHS training of students. The majority of the chemicals we use have little or no toxicity data. On the old MSDSs you would usually see, an LD50 or two and then NOTHING else. And manufacturers were thrilled to see that users were dumb enough to assume that that acute toxicity was the only harm the chemical could cause.
One of the purposes of the GHS SDS was to debunk this assumption by providing 10 blanks for the 10 gold standard toxicity test and then either provide the data or tell the consumer that there was "no data available" for that type of toxicity. But that requirement was left as optional by US OSHA. So you still are used to seeing SDS without the information saying there is no chronic data.
However Sigma is an exporter. So what you see in those wonderful SDSs is the truth as required in E.U. It is why I recommend people go to their website to check the data on their chemicals. If Sigma Aldrich was a nonprofit, I donate for the service they provide. Because otherwise, you have to negotiate the ECHA website which is one of the 7 levels of Hell.
And one other quirk in our laws is even more sinister. All our laws are based on the theory that chemicals are innocent until proven guilty. We can't legislate or claim against a manufacturer unless we have proof that will stand up in court that would prove that a chemical is the cause of any harm. And manufacturers have, as a result, routinely promoted chemicals as safe or even nontoxic when there actually just is "no data available" that would prove otherwise.
I began fighting against this insanity with the art materials labeling practice when asbestos-containing products, even for children, were labeled "nontoxic" because the only tests required under the Federal Hazardous Substances Act (FHSA) were acute tests. So it was perfectly legal to label asbestos as "nontoxic." In 1988, a bunch of us activists managed to get intelligent politicians to pass the Hazardous Art Materials Labeling Act and it was adopted as an amendment to the FHSA. And shortly after, CPSC applied the principles to all consumer products. So after 1988 manufacturers finally had for warn about KNOWN chronically toxic ingredients.
But we were young and dumb, so we didn't realize that there was so little information on most of the chemicals in art materials that all those untested chemicals would still be labeled "nontoxic." So I can show you many, many ingredients, used even in children's art materials, that are in chemical classes that an intelligent person would know will cause cancer or other chronic effect if they are ever tested for chronic hazards.
But with the new GREEN products, we are seeing an even more egregious form of this safe labeling of chemicals. As long as the chemical is made from, or extracted from, renewable sources such as plants, it can be advertised as safe by default. The example in my powerpoint is the following. For hundreds of years, people ingested phenolphthalein in their laxatives. Even Ex-Lax contained phenolphthalein -- until 1992 -- when the cancer test results were finally available. FDA immediately banned it. Ex-Lax and many others switched to "natural senna" which also has been used for hundreds of years without testing. I use Sigma Aldrich's SDS to show that ALL 10 toxicity blanks for natural senna carry the words "no data available."
I KNOW some of you are bored to tears because I've told this story before, but Ralph, you wouldn't have asked this question if you had these facts in you mind every time you read product literature or an SDS. And THAT'S my objective with you ALL. NEVER assume any chemical has had ANY test until you see the results of that test on the SDS. Do NOT let those sweet young things in your chemistry classes graduate without understanding this massive issue.
I will address your second question in a the next email, because it is equally interesting.
From: Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Apr 26, 2019 8:12 am
Subject: [DCHAS-L] MilliporeSigma Introduces New Greener Solvent, Cyrene=E2=84=A2
After reviewing the SDS for this new product, I have a philosophical question:
Can a "Greener Chemical" have a "no data available" section on it's SDS?
That is, shouldn't a complete hazard assessment be required before such a claim is made? It seems to me that a SDS provides the outline of the various aspects of a chemical's hazards that should be systematically investigated before such a conclusion is reached...
Oddly, Section 12.1 Toxicity Data says "No data available" and then lists some data.
BURLINGTON, Mass., April 24, 2019 /3BL Media/- MilliporeSigma today launched Cyrene=E2=84=A2 - a sustainable dipolar aprotic solvent, produced in two steps from a renewable cellulose source. The bio-derived alternative was created in response to the need for solvents to meet stricter regulation requirements for both employee safety and environmental sustainability. The new product targets the rising demand for greener alternatives to Dimethylformamide (DMF) and N-Methyl-2-pyrrolidone (NMP).
"With a strong focus on green chemistry, MilliporeSigma is dedicated to providing today's scientists with innovative solutions to help solve environmental challenges before us," said Klaus Bischoff, head of Research Solutions, MilliporeSigma. "As a greener alternative, Cyrene=E2=84=A2 solvent allows our customers to improve the safety of their processes and reduce the environmental impact of their research and manufacturing - without compromising performance."
MilliporeSigma uses the 12 Principles of Green Chemistry that were developed and published by thought leaders Paul T. Anastas and John C. Warner in 1991 as a framework for its Green Chemistry practice.
DMF and NMP are under increasing regulatory restrictions, with both being classified by the European Union's Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) as substances of very high concern. More recently, according to the European Union, the European Commission added NMP to the restricted substances list known as REACH Annex XVII - driving the demand for alternatives. Additionally, effective May 2020, consumer products containing more than 0.3 percent NMP will be prohibited in the European Union. Initial studies and testing have found Cyrene=E2=84=A2 solvent to be a more sustainable, safer option when compared with DMF and NMP.
<more information at URL above>
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
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