From: ILPI Support <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] A Conundrum
Date: Mon, 26 Sep 2016 19:58:43 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: D861BE88-33C1-48FB-B250-FC8401A459F2**At_Symbol_Here**ilpi.com
In-Reply-To


Just to clarify, folks:

1. If you use a consumer product in an occupational setting, an SDS is ONLY needed if you use it a manner that differs from typical consumer use.  So if you use Windex in the office to clean your windows with the typical frequency you would in a home, an SDS is not required.  If your job is to clean windows all day with Windex, then you have an occupational exposure and an SDS is required.  It's a very common sense regulation.  See http://www.ilpi.com/msds/faq/partb.html#consumer for additional links.

2. Just to reiterate, SDS's are ONLY required for substances that meet the OSHA definition of hazardous and are not otherwise exempted; see http://www.ilpi.com/msds/faq/partb.html#required for a discussion of exemptions.  Water does not require an SDS regardless of the source or use (not intrinsically hazardous), a roll of copper wire for use in electronic repairs does not (it's an "article"), and copier toner does not (office and school supplies) unless it is your job to service copiers all day long.

Rob Toreki

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On Sep 26, 2016, at 4:46 PM, Lawrence Tirri <larry.tirri**At_Symbol_Here**UNLV.EDU> wrote:

An interesting discussion, but I think the real question is how the substance is used?  Is it used in a laboratory or industrial production setting, or is it a consumable used in the home or some domestic situation?

If the substance is used in a laboratory or production setting, not as a consumable consumer product, a SDS is needed.  

I seem to recall that language to this effect was included in the hazard communication and is addressed by U. S. OSHA in an interpretation found on their website.


Dr. Larry Tirri

Department of Chemistry and Biochemistry

University of Nevada, Las Vegas

Las Vegas, NV 89154-4003

702-895-4281

larry.tirri**At_Symbol_Here**unlv.edu

 

"The only two certainties in life are change and death.  If we choose to embrace change and become part of the process, we leave behind a legacy that will live on forever, or you may choose the alternative."


On Mon, Sep 26, 2016 at 1:04 PM, Clark, Eric J. <clarkej**At_Symbol_Here**lattc.edu> wrote:

It's just as important to find out if a chemical is relatively harmless/safe as it is to find out how dangerous it is.  If someone was not aware of exactly what HPLC grade H2O is, he or she might assume the worst and refuse to handle it.  The whole point of having the SDSs available is for the people who are not familiar with the material. 

 

"What is H2O4?" 

"Drinking, washing your hands, bathing, watering the plants - , "

 

Eric

 

Eric Clark, MS, CCHO, CHMM

Environmental & Occupational

Health & Safety Specialist

Adjunct Chemistry Instructor

Los Angeles Trade Technical College

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of James Saccardo
Sent: Monday, September 26, 2016 11:45 AM


To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A Conundrum

 

I think that this question demonstrates how imperfect the laws are with respect to safety data. I've never saw anyone rush for an msds when there is a water leak, spill, etc. nor refer to one, ever. We probably have an sds for hplc grade water...it's semantics. 

 

What's more important here is that water in the workplace is labeled (and its associated hazard). Often water is not labeled because ....well, hey, its just water... But when a clear liquid that looks like many other clear liquid chemicals is leaking or spilled ... You want to know its just water and not a solution of something other than 99%+ H2O that looks just like water. ( famous last words -"it looked like water").

Improper labeling can get people injured and spur unwarranted emergency response.

When water is properly identified anyone can clean it up with the ordinary supplies and no PPE without suffering unnecessary exposure to hazardous aqueous solutions.

 

What you really want is a trace analysis of your water.

 

Ed, why does yours have to be the last water joke, here's a favorite:

Two chemists go into a bar. The first one says "I think I'll have an H2O." The second one says "I think I'll have an H2O too" - and he died.

 

Be well,
James Saccardo, MPH, CHMM

The College of Staten Island

Office of Environmental Health & Safety

 


On Sep 24, 2016, at 9:04 AM, McGrath Edward J <Edward.McGrath**At_Symbol_Here**REDCLAY.K12.DE.US> wrote:

I think Edward Movitz has answered the conundrum:  it boils down (sorry, couldn't resist) to the origin.  If water is purchased from a chemical supply company,  the company must provide an SDS according to GHS.  If water is piped in through the plumbing,  there are regulations for what comes out of the spigot..    I keep a copy of an SDS of H2O as liquid water on hand for my schools.  

 

However,  recognizing that my world is the K-12 science classes, the two main hazards posed by water (absent other chemicals) are 1) dangers of boiling water and 2) the slippery and almost invisible nature of water spilled on a linoleum floor.  Neither of these appears on the SDS but both have resulted in student (and teacher) injuries. 

 

One more water joke:

 

Johnny was a chemist's son

But now he is no more.

For what he thought was H2O

Was H2SO4.

 

Cheers everybody

 

Eddie McGrath 

 

 

 

Sent from my Galaxy Tab =AE A

 

 

-------- Original message --------

Date: 9/24/16 8:06 AM (GMT-05:00)

Subject: Re: [DCHAS-L] A Conundrum

 


On Sep 24, 2016, at 5:28 AM, Patricia Redden <predden**At_Symbol_Here**SAINTPETERS.EDU> wrote:

You might want to check out the website www.dhmo.org, which has an MSDS for dihydrogen monoxide (DHMO).

 

Pat Redden

 

On Fri, Sep 23, 2016 at 2:01 PM, Ben Ruekberg <bruekberg**At_Symbol_Here**chm.uri.edu> wrote:

My curiosity will not allow me to wait until April first, when it might be more excusable, to ask this question.

 

There is a chemical which can be found in almost every laboratory.  Most laboratories even have it piped in.  There are (M)SDSs for this material and yet, while I am told that we are required to have the (M)SDS for each of the chemicals in our laboratory on hand,  I don't believe that many laboratories keep a copy of the (M)SDS for this substance in print.  I refer, of course, to water.

 

OK, I hear you saying "Of course no one has the (M)SDS for water on hand.  It's water."  And I agree: I mean it's in the safety showers, we wash our hands with it before leaving the lab.  But it's a chemical.  I can understand why I would make an exception for it, but does OSHA? 

 

Can anyone tell me why safety documentation is not required for water?  Or is it?  Or is it, but no one makes a fuss about it?

 

Thank you very much,

 

Ben

 

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