From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] Good idea or maybe not for SDSs
Date: Wed, 8 Jan 2020 12:52:13 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 710D39C9-F3B4-410A-B171-1530A1CDA1A2**At_Symbol_Here**
In-Reply-To <00bb01d5c644$a5e87b50$f1b971f0$**At_Symbol_Here**>

You wrote "Well-meaning teaching assistants, who do not have instructions on what action to take depending on the size of a spill..."  That's the problem, not the SDS.  SDS's are one part of the Hazard Communication Standard which covers labeling, SDS's and employee training, (and SDS's do double duty as part of the training).  I am sure some here will report that their laboratory training includes spill response, but in my academic experience (which is a bit dated now, but involved 5 major universities) I was *never* given any training in spill response.  None.  Never saw a spill kit, in fact.  And that's just Plain Bad.  I am sure our peers here will happily point us to their resources for such training, though!

SDS's are designed for the chemical in the form as it leaves the factory.  Just because it's in a 500 mL bottle doesn't mean that's not on a pallet full of bottles, so one does need to consider the industrial worst case scenario.  But it doesn't (and can't) anticipate every real world situation. For example, what about dilute solutions?  That's been discussed here on the list previously: 

In the end, you're absolutely correct - only the best SDS's do actually tell you what to do for small spills and those SDS's are rare.  We can only lobby manufacturers to improve the instructions, however the problem there is that many have absolutely no idea themselves or don't want to dip their toe in that liability pool.  Making this a legal requirement would be a regulatory morass - "small" depends on the properties of the material and it would take pages upon pages to describe the procedure to define "small" for each chemical.  The Hazard Classification process is already a mind-numbing exercise as it is.  Take a look: 

SDS's made less scary here:  Bob Belford and I did a collaboration a some years back making that part of an undergraduate course:

To channel Steve Ballmer, it's all about training, training, training.

Rob Toreki

PS: If you miss that last cultural reference, do a search on "Steve Ballmer" and "developers".

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On Jan 8, 2020, at 11:57 AM, Ben Ruekberg <bruekberg**At_Symbol_Here**URI.EDU> wrote:

Hello and Happy New Year,
Imperfect as they may be, we rely on SDSs for guidance in dealing with chemicals.
For student laboratories, problems arise that are different from industrial scale problems.  SDSs seem to be concerned with the industrial scale.  Take for examples, what to do in case of a spill.  Would it not be helpful if SDSs were to designate size-appropriate actions?  It seems to me that, generally speaking, spilling a milliliter of sulfuric acid should require a different response from that for the spill of a tank car full of sulfuric acid.  Well-meaning teaching assistants, who do not have instructions on what action to take depending on the size of a spill, will tend to act on the side of caution (we would hope) which may involve unnecessary expense and disruption.   Would there not seem to be practical value in an SDS saying something along the lines of "This amount is a small spill and you should do this, that amount is a medium spill and you should do that, more than this sized spill means you should evacuate and call 911!"?  Clearly, what constitutes the various categories of spill size differs from substance to substance, which is why the SDS would seem (to me) the appropriate place for this information.  There might even be the benefit of making some SDSs less scary.  
This might be asking a bit much from documents that say to wear appropriate gloves without saying which gloves are appropriate.  Should I just put this in my next letter to Santa?
Thank you very much,
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