The precautionary principle doesn't have to be in the SDS, it is just something I would cover in training on that SDS. This listing of the 10 tox tests and the mandated "no data available" wording is already in the E.U. SDS rules for single chemicals, and in the UN version as well. It was specifically dropped by US OSHA when they adopted GHS. And I make it very clear how specific and deliberate this act was. I have no trust left in our institutions even when we get people appointed to run them that have good records. It breaks my heart to say it, but OSHA just doesn't work, never has, never will.
We especially saw this in the pandemic. And I have seen a different system that does work. The 4 film industry unions hired their own 10 experts (I was one), set up their own plan, and enforced it through contract negotiations. The film industry stayed open all through the pandemic. We can't make money if we aren't open. And unlike the essential industries that opened and killed their own workers to do it, we can't make money of any critical person on a film location gets sick. If you are going to keep the star healthy, you damn well have to keep everyone else healthy, too. We kept abreast of the literature, so we knew it was airborne from day one -- something the CDC conceded more than a year later. We used only the best tests, did our own tracing and quarantining, I set the ventilation standards and we enforced them, we were recommending N95s a year ago for the crew, and so on. I think you might all want to consider our model for universities. OSHA never can get you for violations if you follow your own regulations, and they are clearly BETTER than OSHA's.
BACK to the SDSs. The SDS without the proper Section 11 is ONLY valid for a US manufacturer providing the SDS to a US customer. But when you look at a US SDS specifically written for export products such as the Sigma SDSs, you will see section 11 done as it should be with all the "no data available" statements. That makes it possible for me to train using some US manufacturer's faulty SDS alongside an export version of the SDS for the same chemical from a different manufacturer (or an EU SDS on the same chemical.)
I can't tell you how jolting this SDS comparison exercise can be for the trusting souls who foolishly allow me to mess with their complacency.
Monona
-----Original Message-----
From: neal**At_Symbol_Here**chemical-safety.com
To: 'Monona Rossol' <actsnyc**At_Symbol_Here**cs.com>; DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Jan 17, 2022 2:11 pm
Subject: RE: [DCHAS-L] OPR&D article: When Safety Data Sheets are a Safety Hazard
Monona:
Your wish (paragraph 1, below) will require petitioning OSHA to add the requirement. This is a good time to do it. It is not hard as it is simply a format change to section 11.
I do not quite understand where you want the discussion of the Precautionary Principle. Isn't this a risk discussion? I do not see an SDS as the appropriate place for the discussion. Also, by "… would alert consumers" are you referring to the chemical end-user EMPLOYEE or to retail consumers?
Keep up this valuable discussion
Neal
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Monona Rossol
Sent: Monday, January 17, 2022 10:53 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] OPR&D article: When Safety Data Sheets are a Safety Hazard
Ralph, Chemical reactivity, even under the GHS is not properly addressed. I agree.
One of the things I want is just so simple. I just want the required listing of all 10 toxicity tests in Section 11 and when they have never been done to clearly indicate this with the words "no data available." This simple requirement along with a discussion on the Precautionary Principle and that in the absence of data, it is not wise to consider a chemical safe would alert consumers. Instead, they find one old LD50 and no other information and consider the chemical "safe" if not ingested.
The original impetus for REACH was the massive numbers of chemicals available (CHEM CAT says 32 million unique chemicals are now available) and the paucity of chronic data (a little over 1000 chemicals with IARC classifications). And my big beef is the 30,000 or so HPV chemicals they identified that have no chronic data. For gosh sakes, this is just nuts.
R & D = step1) synthesize a new chemical and step 2) find a market for it. People need to KNOW that is the case and when it is clearly understood by the average person, their collective common sense will kick in.
> >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 is interesting to note that the UK is facing this problem now that it has exited the EU and the UK government decided it wanted to go its own way on chemical safety information, in the name of loosening "restrictive regulations". See https://www.natlawreview.com/article/uk-proposes-to-extend-uk-reach-registration-deadline-and-explore-alternative for the tip of that iceberg.
In my mind the more interesting aspect of the OPRD article is that it comes on the heels of our discussion of sources of chemical reactivity information. The article serves as a reminder that SDS are designed around each chemical in isolation and that chemical reactivities are quite irregularly reported on SDSs. I appreciate everyone who shared their "go to" sources for this kind of information. It's great to have this list to work from as the need for lab risk assessment of chemical interactions arises.
- Ralph
Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org
