From:
Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject:
Re: [DCHAS-L] SDS missing ingredients
Date:
Feb 26, 2018 15:43 UTC
Reply-To:
ACS Division of Chemical Health and Safety
In-Reply-To:
Let me also correct an assumption made by one of the commenters on this thread that since consumer products come under the CPSC, they could fudge a bit on the SDS. Not so. Once that consumer product is brought into a workplace as part of the person's job and will not be used in the amounts or in the ways in which ordinary consumers would be expected to use it, that product comes under OSHA HAZCOM. And that manufacturer needs to meet all of the same rules for that SDS. The title at the top of the document identifies it as an SDS.
I'm alerting my clients not to accept SDSs for which ACMI simply cites their ASTM D4236 consumer certification instead of dealing with the toxicity issues. WRONG they are -- because ACMI certification is based on consumer use as directed. Once it gets in a workplace or professional studio all bets are off on how it will be used. And ACMI KNOWS that most artists do NOT use art materials "as directed."
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
-----Original Message-----
From: Hadden, Susan [JRDUS] [JRDUS] <SHADDEN**At_Symbol_Here**ITS.JNJ.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Mon, Feb 26, 2018 9:49 am
Subject: Re: [DCHAS-L] SDS missing ingredients
Monona,
You hit the nail on the head. My experience is in chemical lab support. I didn't realize that consumer products are on the section of the map labeled "here be dragons".
And I, too, consider Sigma Aldrich to be the best out there. Sorry to hear their quality might be compromised by a corporate merger.
Oh my. Your experience must be with chemicals supplied to chemical labs, because consumer products routinely leave off ingredients from SDS, and a lot of other data,
too. Check out the SDS requirement from OSHA. They con't even require the 10 tests on section 11 to be reported either with data or the lack of testing. They recommend it, but don't require it.
US SDSs are a mess. I'm right now doing an evaluation of products for an art conservation project in a major museum. Those SDSs, both US and Chinese are a disaster.
I'm having to go to the same products distributed by Sigma Aldrich to get the straight poop.
AND NOW TO A BIG PROBLEM: The only decent SDSs readily available in the U.S. are from Sigma Aldrich. But this company is now, as I understand it, Milipore Sigma.
And those Milipore SDSs are NOT good. If the Sigma Aldrich SDSs go a way, we are going to have to find a better source somewhere.
Anyone else out there notice this?
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
New York, NY 10012 212-777-0062
