James,
-With the new requirements of performing a “classification” of the formula in Section 2 along with the required pictograms per classification to author a SDS now requires more sophistication
and I would suggest contacting the Society for Hazard Communication (SCHC) for their GHS course. In addition, your author must have training in Haz Mat to put the proper transport information in Section 14.
-The SDS is a great start as a guidance document for safety training to a user. A safety professional can provide information to certain sections eg Personal Protective Equipment (PPE) and some
tox experience is needed for the Sections 11 and 12.
- That said, if there is an adverse incident while using the material, the author may be called in to testify if there is a lawsuit and/or serious harm. I speak from experience as I have testified
on several occasions ( 4 hrs. deposition on one MSDS statement. The testimony included How a hazard determination was conducted which led to the statements) So yes there are liabilities for inaccurate information. In my example above, the opposing side was
looking for a way to disprove my hazard review to discover inaccurate information. It didn’t work, I was right. Generally speaking, sometimes people tend to look at a MSDS/SDS as a piece of paper with information on it but the correct application is to go
over it with the person who use the material to insure they are safe when exposed.
Hope this helps,
Michael A. Buczynski
Director Regulatory Compliance
North America
RB (Reckitt Benckiser)
399 Interpace Parkway
Parsippany, NJ USA 07054-0225
Be green keep it on the screen.
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu]
On Behalf Of James Stubbs
Sent: Friday, December 11, 2015 9:59 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] SDS Preparation for New and Novel Chemicals Created in Research Labs
Greetings All,
I work for a large research university and we, like many of you, have researchers on our campus that create new and novel chemicals from time to time and then need to ship them to colleagues across the country. My questions deal with the
SDS preparation for these new and novel materials: What is the comfort level with a self (researcher)-prepared SDS when we offer these materials for shipments? What is the comfort level with a researcher preparing an SDS which then becomes a safety guidance
document for others using the material? What roles does the safety professional play in this process for your company/institution? Are there any liabilities to the institution if the SDS contains inaccurate information?
I have my own opinions but am hoping to tap into the collective wisdom of this group to get a broader perspective.
Many thanks in advance!
-James
