DCHAS-L Archives, Feb 02 2017 - Re: [DCHAS-L] SDS concern

Long-winded answer with a nice solution for your dilution dilemma at the end:

Bob Belford reports that he ran into the same situation in a class and it was a very teachable moment. See http://confchem.ccce.divched.org/2006SpringConfChemP8A and skip down to the Spring 2006 section which describes the scenario. In the Discussion section of the paper he notes:

An unexpected but clear benefit of the web-based MSDS exercise is that students saw firsthand the shortcoming of an MSDS. This is an important lesson. Consistent with the scientific and Socratic methods, we do not want students to believe everything they read, even if it is published in a scientific journal. Healthy skepticism is even more important when students seek information from non-peer-reviewed resources like the Internet (in chemistry or any other topic, for that matter). In fact, a wily instructor might deliberately create an assignment in which two "authoritative" resources conflict.
Seeing that two MSDS sheets from the same reputable manufacturer had contradictory first aid instructions depending on the concentration led to some very interesting discussion. In fact, this question was rephrased and sent to the ACS Division of Chemical Health and Safety's (DCHAS) listserver. It was noted that the MSDS for solid potassium permanganate states not to induce vomiting while that for 0.1N says to induce vomiting. So, if one purchases a solid and makes a 0.1 N solution, what MSDS should you keep on file or refer to in an emergency? Even the members of the DCHAS discussion list could not come to a consensus!

The DCHAS-L entries he mentioned were (keeping in mind the discussion was pre-GHS)

http://www.ilpi.com/dchas/2006/20060525b.html

http://www.ilpi.com/dchas/2006/20060526d.html

http://www.ilpi.com/dchas/2006/20060526e.html

http://www.ilpi.com/dchas/2006/20060527.html

http://www.ilpi.com/dchas/2006/20060527a.html (Best of Monona; Monona rocks as we all know)

http://www.ilpi.com/dchas/2006/20060530.html

Speaking of GHS, HCS 2012 replaced prior versions' hazard determination with a codified hazard classification. =46rom OSHA Instruction, Directive Number CPL 02-02-079, "Inspection Procedures for the Hazard Communication Standard (HCS 2012)", paragraph D.1.h, http://www.ilpi.com/msds/osha/cpl0202079.html#D.1.h (which is basically the OSHA inspector's playbook):

h. Cut-off values/concentration limits.

• The HCS 2012 classification approach does not have one single cut-off value for classification. Each physical or health hazard has its own specified cut-off values for each specific category. See Appendices A and B of the standard for each specific cut-off value. A partial list of cut-off values can be found in Appendix B of this Instruction.

• Under the HCS 1994, a product, if not tested as a whole, that contained 1% of a hazardous component and 99% of a nonhazardous ingredient, was assumed to present the same hazard as the component. This may not be the case under HCS 2012.

• To classify the hazards of a mixture, the manufacturer or importer must use the information contained in Appendices A and B of the standard. This may possibly result in the chemical having a different classification than was previously identified under HCS 1994.

Which is what the other folks were saying.

Now we get to the meat of your question. You are not required to prepare an SDS for a dilute solution you prepare and use within in your own lab (lab as defined by the Laboratory Standard). And we've already determined that if you give the high schools the chemicals, you must provide SDS's to the high schools. That's easy if you're giving them a jar of MgSO4 - just hand them the SDS from your supplier. But if you prepare your own 0.1 M solution and provide it to them, then you need to give them an SDS for 0.1 M solution. Which is probably available from other sources; while technically that's not 100% kosher, it follows the spirit of the law; see http://www.ilpi.com/msds/faq/partd.html#multimanufacturer and http://www.ilpi.com/msds/faq/partc.html#laboratory

So here's my very pragmatic advice (worth exactly what you paid for it): if you find yourself in a situation where you must provide an SDS to the high school for one of your dilute solutions but don't have one you can give them without creating one yourself, give them the solid material for which you have an SDS and have them make up the solution themselves at their location. They then have the SDS which was required when they procured the chemical, and they are creating the dilute solution in their own laboratory, an action which does not require them to create an SDS for that dilute solution. You are compliant and they are compliant and no SDS for the dilute solution is ever required.

Ohmygosh, that's clever. I must pat myself on the back for that last paragraph. Yeah, I know-.does outreach qualify as a lab etc etc. Many layers to that onion.

Rob Toreki

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On Feb 2, 2017, at 8:17 AM, Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM> wrote:

Aniello:

The short answer is, "Yes, it is incorrect to provide an SDS that is not reflective of the stuff in the bottle." 29CFR1910.1200(g)(5) states in part:

"The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification."

There are a boatload of regulations contained in Appendices A and B of the Hazard Communication Standard and in the GHS "Purple Book" on how to determine the classification of the material. Appendix C of HAZCOM gives the required label hazard and precautionary statements as well as the required pictograms for the SDS.

Harry

On Wed, Feb 1, 2017 at 6:15 PM, Tambasco, Aniello <aniello.tambasco**At_Symbol_Here**wilkes.edu> wrote:
Hi-

Please let me start to wish Monna Happy Birthday!!!!

My concern is the following. We run a Chemistry Outreach program to local high schools.We provide some different types of equipment and small quantities of chemical solutions to these sites. I was questioned today by an individual that came from industry and now is working in academia. The concern was that the SDS should reflect not only the chemical but the form it is in. For example, I prepared a 0.1M Magnesium Sulfate solution. I usually provide an SDS of Magnesium sulfate heptahydrate solid and not of the solution I prepared. Is that wrong? I researched OSHA and did not see anything in the language? Is there anything in the new GHS system? I could not find anything. I appreciate everyone's help and input.

Thanks,
Aniello Tambasco
Lab Tech. & Assistant
Wilkes University Chemistry Dept.
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