DCHAS-L Archives, Jun 11 2019 - Re: [DCHAS-L] What is happening to the GHS SDS?

Rob, the Categories all have mandatory hazard warning words and phrases that must be used with them on the labels. So they done did that already. And the warning words are mandated by the data precisely to keep suppliers and manufacturers from spinning them. The old MSDSs are practically promotional material for the product.

I think you are just finding that many of the US SDS still aren't doing this right. That's the fault of the people writing the SDSs, not the GHS system. The whole point was to get away from the meaningless wording I am still seeing on US SDS. The best example is the misleading statement: "Not listed as a carcinogen by IARC, NTP and OSHA" when a simple GHS "no data available" would be vastly more correct. We are the only country that demands to use that statement when we KNOW that workers think it means the stuff is not a carcinogen.

I'd like to see us cold turkey away from HIMIS and all the other nonsense that caused the EU and many other countries to adopt the UN Purple book in the first place. And that includes changing the OSHA exemption to not indicate when data is not available on Section 11. That is something the workers really NEED to know.

You, I and Pogo already know who the enemy is.

Monona

-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Jun 11, 2019 10:15 am
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?

This is nothing new at all. (M)SDS=E2=80™s have always contradicted each other since the earliest days. As each manufacturer is responsible for coming up with their own sheet, the quality of the output depends on the quality of the input and the competency of the author. The fox has always been in charge of the (M)SDS writing henhouse.

The two biggest factors making these differences all the more glaring/vexing are:

1. Now that we can easily search aggregated sources of information (see Ralph, below) and the hazard classifications appear in sheets in a standardized place and format, we can immediately see these contradictions that would have formerly required extensive searching and comparison by hand.

2. One would think that as the Appendix A of 29 CFR 1910.1200, the OSHA HazCom Standard provides a much better "flow chart" and standardized approach to the classification process (formerly called hazard determination) that the quality of the assessment would improve. While parts of that are straightforward, others are mind-numbingly complex. I invite you to look here http://www.ilpi.com/msds/osha/1910_1200_APP_A.html#A.1.3 and here http://www.ilpi.com/msds/osha/1910_1200_APP_A.html#A.1.3 as two examples and put yourself in the perspective of perhaps a B.S. chemist or staff member at a small chemical company.

While we would like to think that the major companies have staff on hand that can comprehend and make prudent professional assessments to arrive at similar conclusions, remember that not everyone starts with the same data set and not all companies have the same priorities. And, at other companies, no such in-house expertise exists. Some will outsource the task to consultants or firms with varying levels of expertise and others will try to figure it out on their own. The result is wildly differing classifications even though the rule book is the same for everyone.

Going back to Monona's original observation/question:

I'm hoping someone can tell my why, after we finally have a good system of describing acute and chronic toxicity with the GHS dose-response Categories, I'm suddenly seeing the misleading dumb old HMIS one number toxicity system showing up even on the new Sigma SDS for Cyrene.

The single biggest flaw of all of these systems is the odd insistence on using numbers or symbols where words are needed. I've warned of this for decades as noted on several of my MSDS HyperGlossary pages such as the one for HMIS =AE: http://www.ilpi.com/msds/ref/hmis.html Scoot on down to the PPE section for commentary. Who in their right mind thought that a substance that requires safety glasses, gloves, and a vapor respirator should simply have the letter "G" to indicate this on the label? Like workers are going to memorize that table. Or the employer is going to have a chart. How hard is it to write this out in words? How does "G" tell the worker that nitrile gloves are required instead of latex?

Numbers for degree of hazard (using scales which are opposite for GHS and NFPA/HMIS)? And the writers of GHS had to know they were contradictory. How about instead of 1 or 4 you write "HIGHLY TOXIC". How simple would that be? How many workers even know the scales are 1-4 and not 1 to 10 let alone which end is the bad one?

It seems that along the way, someone forgot that the HazCom standard has the word "Communication" in the title. The pictograms are a big improvement, but, as we just discussed, they can't help you if they aren't on the SDS and label when they should be.

Rob Toreki

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On Jun 10, 2019, at 7:22 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:

Today, I unboxed a new chemical and noticed that it did not have all the required GHS pictographs on it. The substance was calcium nitrate ... no oxidizer symbol.

This is an interesting point. The PubChem Lab Chemical Safety Summary for calcium nitrate
https://pubchem.ncbi.nlm.nih.gov/compound/24963#datasheet=LCSS =A7ion=GHS-Classification
lets us know that there is significant disagreement within the European Chemicals Agency (ECHA). Only irritant is assigned by more than 60% of the notifications on this chemical:
- Aggregated GHS information provided by 718 companies from 25 notifications to the ECHA C&L Inventory. Each notification may be associated with multiple companies.
- Reported as not meeting GHS hazard criteria by 4 of 718 companies. For more detailed information, please visit ECHA C&L website
- Of the 24 notification(s) provided by 714 of 718 companies with hazard statement code(s):
- H271 (10.36%): May cause fire or explosion; strong Oxidizer [Danger Oxidizing liquids; Oxidizing solids]
- H272 (27.03%): May intensify fire; oxidizer [Danger Oxidizing liquids; Oxidizing solids]
- H302 (34.31%): Harmful if swallowed [Warning Acute toxicity, oral]
- H315 (62.61%): Causes skin irritation [Warning Skin corrosion/irritation]
- H318 (24.65%): Causes serious eye damage [Danger Serious eye damage/eye irritation]
- H319 (66.11%): Causes serious eye irritation [Warning Serious eye damage/eye irritation]

Information may vary between notifications depending on impurities, additives, and other factors. The percentage value in parenthesis indicates the notified classification ratio from companies that provide hazard codes. Only hazard codes with percentage values above 10% are shown.

Thanks for pointing this out.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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