From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
Date: Tue, 25 May 2021 11:52:14 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: D723F1B8-CF3D-42E9-92FB-62A0E2C6FFAD**At_Symbol_Here**me.com
In-Reply-To


SDS quality (and the quality of the data that goes into the SDS) is a major issue. Although the HazCom Standard says that SDS authors "shall identify and consider the full range of scientific data and other evidence," there's no real standards for the quality of the literature search a manufacturer performs, either in the reg, interpretation letters, nor in the compliance inspection manual. Should a SDS writer do a Google search, consult specific government databases (e.g., PubChem, ToxNet, etc.), do a search on SciFinder, or what? There doesn't appear to be an answer.

I asked OSHA a while ago whether they ever actually enforced this provision, but they dodged the question. I'm reformulating the query as a FOIA request: In which inspections since the revised HazCom Standard took effect did they cite based on that requirement? If I get an answer, I'll write a paper on the topic.

Since there appear to effectively be no rules, I expect that SDS writers do literature searches either to the limit of their conscientiousness or to the minimum necessary to alleviate fear of liability. I've got a small collection of "bad SDSs" that contradict one another, list drastically-different hazards for the same compound, or give stupid first aid advice. I particularly like the SDS for H2O that advises that in the event of a skin exposure, one should rinse with water for 15 minutes.

I for one would welcome data search and quality standards for SDSs.

Regards, Dan Kuespert

Sent from my iPad

On May 25, 2021, at 11:33, Hunt, Alessandra <alehunt**At_Symbol_Here**msu.edu> wrote:

=EF=BB=BF

Could we have a webinar or discussion about the differences in SDS? I have faced those many times and depending on the manufacturer there are really big differences.

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Tammy M. Lutz-Rechtin
Sent: Tuesday, May 25, 2021 11:14 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.

 

Prudent point. 10/22/2020 for Sigma  and PubChem was modified last in 05/22/2021 but created in 2005. 

Regardless of the date, I need to understand the reasoning behind any reclassification in order to assess correctly. Older information is still pertinent and quite honestly more helpful sometimes. I am not finding a good paper trail on this chemical.

 

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Jennifer L Herriges
Sent: Tuesday, May 25, 2021 9:57 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.

 

What are the publishing dates of each?  One may have new information

 

Sincerely,

 

Jennifer Herriges

Laboratory Safety Coordinator

University Safety and Assurances

University of Wisconsin - Milwaukee

 ***In respect of social distancing, I will be working remotely when possible. You may reach me via phone

Cell: 414-430-7508

Teams phone number: (414) 251-8977 

herrigej**At_Symbol_Here**uwm.edu


From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Tammy M. Lutz-Rechtin <tlutzrec**At_Symbol_Here**UARK.EDU>
Sent: Tuesday, May 25, 2021 8:11 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: [DCHAS-L] Pentadecafluorooctanoyl chloride.

 

Has anyone worked with or know why the SDS from Sigma is drastically different than PubChem for
Pentadecafluorotoctanoyl chloride?  Is this chemical a super acid like some fluoro compounds or is Sigma more correct?

Tammy Rechtin
Univ of Arkansas
Safety Coordinator
Tlutzrec**At_Symbol_Here**uark.edu

Sent from my iPhone

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