From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] OPR&D article: When Safety Data Sheets are a Safety Hazard
Date: Sat, 15 Jan 2022 14:03:03 +0000
Reply-To: Monona Rossol <actsnyc**At_Symbol_Here**CS.COM>
Message-ID: 220197145.980820.1642255383409**At_Symbol_Here**mail.yahoo.com
In-Reply-To


Thanks Ralph.  The article said:   "The Globally Harmonized System for Hazard Communication (GHS) was adopted by the United Nations in 2003. Starting in 2013, the GHS became mandatory in the United States."

I have to wonder why authors don't say more correctly that the E.U. gave us until 2015 to do it after which they would no longer accept our exports so the US made it mandatory in 2013 and required SDSs be available by the 2015 deadline.  It would explain to people why the SDS was suddenly a reality in their readers labs and lives.  Instead of decades of wrangling, lawsuits, and federal register accounts of the experts and pols arguments, this new rule just slid quietly into place before many people even knew it was coming.

I'm just sorry the EU got chicken and didn't enforce their 2018 deadline on their "no tests, no market" REACH ruling on the 30,000 high production volume chemicals they identified in commerce that have no chronic data.  The US isn't going to test these chemicals without pressure from other countries. And the tests being done in the US under what's left of the Chemical Safety Act are 20 or so of the old bugaboo chemicals that we already had enough data to know they weren't good for us. The 30,000 high production chemicals in our products that we are actually all exposed to regularly are not on those lists.

As for the cost, if you are selling thousands of tons of a chemical can can't afford around $200,000 for long term cancer assessments, you need to find out which of your bookkeepers has their hand in the till.

Researchers who opine about why certain cancers or chronic diseases are on the rise are utterly off base in their calculations because they don't know anything about the chronic toxicity of the major chemical exposures most people have in their daily lives from the products they use. Instead, they look for the known bugaboos to pin it on.  

And the fact that industry and EPA are pushing in silico testing to save money is an insult to intelligence.  To have a good computer analysis system for assessing toxicity without testing requires a lot of real data on many chemicals for comparison and we don't have it.  Hell, a couple years ago a new metabolic pathway was discovered.  How much more is there we don't know?  Maybe if we actually test the 30,000 high production volume chemicals, we will actually have enough data to set up a reasonable in silico toxicity assessment tool. 

Monona


-----Original Message-----
From: Ralph Stuart <membership**At_Symbol_Here**DCHAS.ORG>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Sat, Jan 15, 2022 7:15 am
Subject: [DCHAS-L] OPR&D article: When Safety Data Sheets are a Safety Hazard


When Safety Data Sheets are a Safety Hazard
Alexander G. Kolchinski*

Over the past several decades, Material Safety Data Sheets (MSDSs) and, more recently, Safety Data Sheets (SDSs) have become a valuable source of safety information for both industry and academia. They provide chemists with important data on reactivity, toxicity, decomposition byproducts, etc., thus preventing various chemical accidents. Conversely, when the SDS contains erroneous information, serious accidents can ensue. This article provides examples of erroneous statements found in SDSs and analyzes their origins. Several measures are also proposed to improve the quality of SDSs.

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