From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] SDS and label software
Date: Mon, 15 Jul 2019 17:33:22 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 413982088.1562069.1563212002813**At_Symbol_Here**mail.yahoo.com
In-Reply-To <96B01B2E9C84674ABE1BA48CDA33910303E7AA9F74**At_Symbol_Here**BPMAIL.bpi.local>



...some ingredients (glycerine, oleic acid, PIB) are not GHS-classifiable and in moderation truly don't contribute to any hazards.
 
I would just ask you to look at Sigma Aldrich's SDS on glycerin as a case in point.  Except for a couple of LD50s, NONE of the 10 SDS toxicity tests have ever been done on glycerin.  

The TLVs have been withdrawn for "insufficient data...."  And the MAK is only for inhalable mist.

There is some anecdotal stuff from RTECS noted on the SDS as:

RTECS: MA8050000
Prolonged or repeated exposure may cause:, Nausea, Headache, Vomiting, To the best of our knowledge, the chemical,
physical, and toxicological properties have not been thoroughly investigated.
Kidney - Irregularities - Based on Human Evidence

So why does everyone assume there are no toxic issues?  Because I can tell you that when you make it into a one micron mist, call it "haze" and suspend those particles in quantity on a stage, there are people who have issues.   

When are we going to finally consider the Precautionary Principle that says in the absence of data you cannot assume a chemical is safe?   And safe in ALL ways by ALL routes of entry?  That's just dumb.

To use a PROVEN example: Mineral oil is another "safe" chemical.  But mineral oil fog and haze has also been documented to cause EXACTLY what you would expect in those over exposed:   lipoid pneumonia.   

And while you my retire from ranting, I live to rant.     Monona


-----Original Message-----
From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Mon, Jul 15, 2019 12:55 pm
Subject: Re: [DCHAS-L] SDS and label software

Monona, you are correct in assuming that we do not sell into the theater, but we certainly have our own industry geniuses to consider.  We primarily sell automotive aftermarket chemicals, so my "secret ingredients" are typically going into fuel additives, engine oil top treats, and a few aerosol lubricants.
 
As I mentioned to another list member offline just a bit ago, these formulas are the result of thorough research, hard-to-come-by lab time, 20-something years of experience/expertise, etc.  These formulas are my babies; that's why I'm so protective of them.  I understand RTK/RTU.  I really do.  It's just frustrating to be held hostage for 100% disclosure when some ingredients (glycerine, oleic acid, PIB) are not GHS-classifiable and in moderation truly don't contribute to any hazards.
 
I said I'd quit ranting after the last e-mail.  I mean it this time.
 
Dan
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Monona Rossol
Sent: Saturday, July 13, 2019 9:26 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] SDS and label software
 
But don't forget to register it in New Jersey.  We watch for unregistered trade secret ingredients and make a fuss when needed.  
 
And while I'm sure the products you are talking about are not used in art or theater work, I can tell you as a union rep, any "trade secret" or "proprietary" ingredient means we are probably no going to approve of it for use.  Products used in art and theater rarely are used "as directed," so we dang need to know what's in it before the geniuses start to play with it.
 
Monona

-----Original Message-----
From: Michael <mabuczynski**At_Symbol_Here**HOTMAIL.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Sat, Jul 13, 2019 5:35 am
Subject: Re: [DCHAS-L] SDS and label software
Dan
You can always designate some ingredient as Trade Secret and it will not be disclosed a on the published SDS. The software needs the complete formulation to calculate the GHS classifications
 
Hope this helps
 
Mike Buczynski

On Jul 12, 2019, at 8:31 PM, Dan Nowlan <dnowlan**At_Symbol_Here**berrymanproducts..com> wrote:
I suspect I'll get little sympathy from this group but as a formulator, I absolutely HATE using Wercs. Not only is it cumbersome to navigate, but I feel like nobody outside the company needs to know ALL our secret weapons if they are not posing health risks not otherwise represented by another ingredient. If I'm using non-haz components (by design!), that should be my business. Glycerine? PG? GMO? Who cares. They shot me down just the other day for not disclosing 50 ppm amylene in a 60% methylene chloride formula. Seriously?!
  
Dan
  
Sent via the Samsung Galaxy S7, an AT&T 4G LTE smartphone
  
 
 
-------- Original message --------
Date: 7/12/19 6:24 PM (GMT-06:00)
Subject: Re: [DCHAS-L] SDS and label software
 
Neal
UL's The WERCS software dies GHS SDS in approximately 70 languages.  It can also do labels.  We used it for many years in my company.  I am retired but they are still using it.
Kitty Strang
 

On Friday, July 12, 2019 NEAL LANGERMAN <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> wrote:
All 200 SDS's and labels need to be in 50 languages
 
Sent from Neal Langerman's NEXUS 6.
Standard client confidentiality terms apply.
 
On Fri, Jul 12, 2019, 14:00 Peter Zavon <pzavon**At_Symbol_Here**rochester.rr.com> wrote:
50+ languages or 50+ SDS to be translated?


Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com



-----Original Message-----
From: ACS Division of Chemical Health and Safety
[mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of NEAL LANGERMAN
Sent: Friday, July 12, 2019 3:16 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] SDS and label software

All

I need some suggestions for SDS and label generating software that handles
both the GHS SDS and GHS label and produces results in many languages.  My
immediate language need is for 50+ translations.

Thanks for your ideas

Neal

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