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Subject: Re: [DCHAS-L] Legacy chemicals and old MSDSs

Date: Jun 6, 2025 16:37 UTC

Author: Alex Hagen <fischera**At_Symbol_Here**UW.EDU>

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Subject: Re: [DCHAS-L] Controlled pyrophoric fire?

Date: Jun 6, 2025 17:05 UTC

Author: Kolodziej, Christopher <ckolodziej**At_Symbol_Here**EHS.UCLA.EDU>

From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>

Subject: Re: [DCHAS-L] Legacy chemicals and old MSDSs

Date: Jun 6, 2025 17:05 UTC

Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>

Message-ID: <2101750941.414327.1749229528935**At_Symbol_Here**mail.yahoo.com>

In-Reply-To: <CAAy2tW8jrn31xU5Yq2-YSD6PSg7gNafAeYBFaZ18dEkmNtbcTg**At_Symbol_Here**mail.gmail.com>

Demystify: 
While you were at those schools, you should have prowled around in the art departments, shop classes, and, if they had a theater program, the costume, makeup, scene and prop shops.  This is not just a problem in the science departments.  And the difference is that in the art and entertainment areas, teachers are even less chemically sophisticated and most are convinced that those old chemicals can be used by anyone who is creative and everything is safe. And they are aided by the art and theater material manufacturers in this delusion.

You realize that all this could have been nipped in the bud if the OSHA hazcom rules had just been enforced right from the beginning in the early 80s when states were passing Right to Know laws and later 80s when Hazcom was instituted..  If there would have been yearly training of the teachers on the chemicals they actually have in their departments, if they had to have up-to-date (M)SDSs on all these or dispose of them, and if all those materials had to be on an inventory, they would have been motivated to reduce their chemical holdings before they were so far out of hand.

And maybe, just maybe, some of the hazcom chemical training would have been put in the curriculum for students who now graduate without a clue about these issues and having never even heard of their rights to a safe workplace even though most of them have jobs by this time.  Another opportunity to make HS education relevant down the toilet.

Monona


On Friday, June 6, 2025 at 11:56:46 AM EDT, Stephen Taylor <stephen**At_Symbol_Here**labsafetyinstitute.org> wrote:


Here is a blog I just posted regarding this topic. You can see a couple of images from 3 different schools.

(38) The Silent Hazard: A Pandemic of Legacy Chemicals in Our Schools | LinkedIn

Stephen Taylor, Ph.D.
Executive Director
The Laboratory Safety Institute
Stephen Taylor | LinkedIn

PS. Be sure to take our Safer Science Self-Assessment to see how your School or University stacks up!


On Fri, Jun 6, 2025 at 10:39 AM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:
That would be great.  You don't even have to do it anonymously, just say I'm shy.

And a 4th question:  If we wanted to keep a legacy chemical for which the manufacturer is out of business, can we write an SDSs as the "manufacturer of record" and take responsibility for the material?  

I'm thinking of a school that found 30 year old 50# bags of a mineral called Albany Slip.  The mines for the slip ran out in the 1980s.  This glaze mineral is very desirable and worth a lot of money.  But like all minerals, it has some hazards.  There are many analyses of this mineral to work up an SDS from.

And there are other substances that people might want to keep.

I'm really interested in this subject. Monona




On Thursday, June 5, 2025 at 11:16:51 AM EDT, James Kaufman <jkaufman**At_Symbol_Here**labsafetyinstitute.org> wrote:


Hi Monona.

Would you like me to ask OSHA anonymously for you.  ... Jim 

James A. Kaufman, Ph.D.
Founder, LSI
Serving Industry, Government, & Academia for 50 years
508-574-6264

On Thu, Jun 5, 2025, 2:29 PM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:
I remember we had a long conversation some years ago about legacy chemicals,so hopefully there are still people on this forum who can give me some guidance on the following questions.

1.  Can OSHA cite an employer who has old MSDSs in their hazcom or lab standard files for workers reference?   

2.  And can they cite if the old MSDSs are for legacy products if the manufacturer no longer makes the product or is out of business?

3.  What are the legal issues associated with using products in the workplace for which the manufacturer no longer claims liability?

I'm desperate for some kind of legal or OSHA guidance on this for some theater shops where we have workers.

Monona

M. Rossol, President
Arts, Crafts & Theater Safety
181 Thompson St., #23
New York NY 10012




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