On Feb 15, 2022, at 10:20 AM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:

That makes sense.  We just have to wait for enough pregnant people to be exposed and look at the data before we act.  Monona

-----Original Message-----
From: Kolodziej, Christopher <ckolodziej**At_Symbol_Here**EHS.UCLA.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Tue, Feb 15, 2022 9:59 am
Subject: Re: [DCHAS-L] TBE Buffer: Conflicting Hazard Clarification

Monique,

 

While boric acid is commonly classified as a reproductive toxicant, the data to support that classification is mixed at best. My (limited) understanding is that reproductive effects have been shown in animal models, but that epidemiological studies in humans have failed to show significant effects. This recent review seems to be reasonably comprehensive for those who want to dig into what's out there:

 

https://doi.org/10.1007/s00204-020-02700-x

 

Chris

 

 

________________________________

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

UCLA Environment, Health & Safety | Chemical Safety

 

Mobile: (310) 261-8611

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Penny Chatterton
Sent: Friday, February 11, 2022 6:00 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] TBE Buffer: Conflicting Hazard Clarification

 

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.

 

Penny Chatterton=E2=80=8B Chemist NOVUS Glass t: +1 952-946-0406 e: pchatterton**At_Symbol_Here**novusglass.com Confidentiality Notice: This e-mail, including all materials contained in or attached to this e-mail, contains proprietary and confidential information solely for the internal use of the intended recipient. If you have received this email in error, please notify us immediately by return e-mail or otherwise and ensure that it is permanently deleted from your systems, and do not print, copy, distribute or read its contents. =E2=80=8B

 

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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