An "article" means a manufactured item: (1) which is formed to a specific shape or design during manufacture (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. Any product which meets the definition of an "article," would be exempt from the requirements of the Standard.
And therein lies the key point as to whether an SDS is required. SDS's are for occupational exposures and usage only (OSHA has no jurisdiction outside the workplace). If you use Tide Pods at your **workplace** in a frequency similar to the typical consumer at work, then no SDS is required. However, if you wash clothes several hours a day or more, then this is outside the consumer product exemption and an SDS is required.
The HCS exempts any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.
"chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition." means
So by these definitions, a Tide Pod is a mixture, a mixture of PVA and the solution inside it. Meets all of our General Chemistry definitions of a heterogenous mixture. And the solution inside is indeed hazardous, so it must be listed on the SDS.
"solution composed of two or more substances in which they do not react." means a combination or a
In addition to the information required for substances: (a) The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards in accordance with paragraph (d) of =A71910.1200 and (1) Are present above their cut-off/concentration limits; or (2) Present a health risk below the cut-off/concentration limits. (b) The concentration (exact percentage) shall be specified unless a trade secret claim is made in accordance with paragraph (i) of =A71910.1200, when there is batch-to-batch variability in the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2) with similar chemical composition. In these cases, concentration ranges may be used.
On Dec 20, 2021, at 1:07 PM, NEAL LANGERMAN <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM> wrote:All:
No question a manufacturer of a laundry detergent pod must provide a
SDS for the contents. See:
The pod itself meets the definition of an "article".
Should the SDS include the polyvinyl alcohol (PVA) pod skin?
If so, what is the exposure anticipated?
Looking forward to the responses.
Stay healthy and stay safe - Pandemic precautions are long-haul!
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