Everyone,

This is a very interesting and some what heated discussion on SDSs. As someone who has authored SDSs for a chemical company I figured I would provide some information that I think people do not know about. First, in present day SDS authors tend to use software that populates an SDS document based on information the author enters. For example for a registered compound I would enter a CAS# and the software pulls in information from various sources, such as TSCA and REACH. Obviously as the author there is some editing power to change based on internal data, customer needs, etc. For new, novel compounds the author has less resources to pull from. Often you look at reagents used to make a product (especially for mixtures) or look at similar compounds and what data is available for them. In theory a compound would go through rigorous testing to be classified, however, test that meet GHS standard are expensive and often not required by TSCA in order to be registered and sold. Also many of the Health Hazard type test are done on animals which opens up a whole new set of arguments. If a company does have a material tested they are not required to share that information or even publish it on their SDS. EU REACH is somewhat more stringent with requirements when registering new chemical products but US SDSs don't often pull in data from ECHA. This all can seem very frustrating, especially to the EHS community, but there is a lot of money involved in these classifications, not just in testing, and until there is a more regulations and standardization it won't quickly change.

Sara Johnson, Ph.D., CCHO

Chemical Hygiene Manager

UNC Chapel Hill Environment, Health & Safety/Risk Management

On Wed, May 26, 2021 at 1:51 PM Kolodziej, Christopher <ckolodziej**At_Symbol_Here**ehs.ucla.edu> wrote:

Tammy,

Good luck getting anything useful out of Sigma. A few years back I was trying to get some clarity from them regarding the classification of tri-n-butylphosphine. According to literature, it has an autoignition temperature of 390 F, but was being classified as pyrophoric. Sigma responded with an updated SDS that replaced the autoignition data with the statement "The substance or mixture is pyrophoric with the category 1."

As an interesting side note, their updated SDS did still provide both oral and dermal LD50 values. I can't recall ever seeing those data points being reported for a material that's truly pyrophoric (nor would I expect to, given the obvious practical and ethical challenges with trying to determine those).

Chris

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

Mobile: (310) 261-8611

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