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Monique,
If you were to make the TBE Buffer yourself with the indicated concentrations of boric acid, both of these mixture concentrations would have to be classified and labeled for Reproductive Toxicity, Category 1. For generic mixtures (where
no testing is performed on the mixture as a whole), the presence of a Reproductive Toxicant in Category 1 at equal to or greater than
0.1% w/w requires the mixture to be classified as such. This is per OSHA's Hazard Communication Standard (Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations, page 17811).
Perhaps the TBE Buffer SDS you reference was made differently? Or the manufacturer has actually sponsored toxicity testing to be able to state that the product is non-hazardous? That
should be indicated in Section 11, if so.
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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Monique Wilhelm
Sent: Thursday, February 10, 2022 10:09 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] TBE Buffer: Conflicting Hazard Clarification
Hi Everyone,
QUESTION: Is the toxic hazard and pictogram required on these labels?
I thought I read somewhere that a label for a mixture does not have to include the hazard of any component less than 1% but cannot easily find it right now. I know carcinogens designations occur at a much lower concentration, 0.001%.
So, is the 1% rule true? Does anyone know of this guideline?
My institution uses ChemWatch Gold FFX for SDS and labeling info. Being a biochemist who always made her own solutions, when I looked up TBE info, I looked up each component. Boric acid is listed as a reproductive poison health hazard
on its SDS. But, the researcher just looked up TBE buffer and it was listed as non-hazardous. The boric acid is at 0.5% when at 1x concentration, but is often made at 10x concentration and later diluted down. Is it still considered hazardous at these concentrations
and require the toxic hazard and pictogram on these labels?
Thank you,
_________________________________________________________
Monique Wilhelm
Lab Manager
CAS, Department of Natural Sciences | The University of Michigan-Flint
303 E. Kearsley St | Room 572 MSB | Flint, MI | 48502-1950
NEW EMAIL ADDRESS: mwilhelm**At_Symbol_Here**umich.edu
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