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Subject: [DCHAS-L] Laundry detergent pods SDS
Date: Monday, December 20, 2021 at 1:07:34 PM
Author: NEAL LANGERMAN <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM> 		Next by Date:
Subject: [DCHAS-L] EPA Takes Critical Step Towards Strengthening Science Used in Chemical Risk Evaluations
Date: Mon, 20 Dec 2021 15:52:25 -0500
Author: CHAS membership

From: Info <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Laundry detergent pods SDS
Date: Mon, 20 Dec 2021 15:02:31 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 5EAFB3F7-B0A6-4649-9BAD-C68873F68AC2**At_Symbol_Here**ilpi.com
In-Reply-To <001c01d7f5cc$775d5da0$661818e0$**At_Symbol_Here**chemical-safety.com>


Neal loves stirring the pot as much as I do, so please follow along this rhetorical journey. Pour some brandy, have a seat in the salon, and enjoy:

A Tide Pod in its entirety does not meet the definition of an article, http://www.ilpi.com/msds/faq/partb.html#article which is:

An "article" means a manufactured item: (1) which is formed to a specific shape or design during manufacture (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. Any product which meets the definition of an "article," would be exempt from the requirements of the Standard.

The key part of that definition is "under normal conditions of use". While, ideally, a pod will only disgorge its contents in a closed washing machine, it is a reasonably foreseeable event that a pod could be stepped on, accidentally cut, be in mid-dissolution when a load of clothes needs to be removed because of a problem with the washer. And since those contents are released in use, are hazardous, and risk of exposure is foreseeable, a Tide Pod is not an article.

However, as noted in the link Neal quoted, https://content.oppictures.com/Master_Images/Master_PDF_Files/PGC50978CT_SDS.PDF , a Tide pod is generally considered a consumer product w.r.t. the HazCom Standard,which contains a consumer products exemption, http://www.ilpi.com/msds/faq/partb.html#consumer 

The HCS exempts any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

And therein lies the key point as to whether an SDS is required. SDS's are for occupational exposures and usage only (OSHA has no jurisdiction outside the workplace). If you use Tide Pods at your **workplace** in a frequency similar to the typical consumer at work, then no SDS is required. However, if you wash clothes several hours a day or more, then this is outside the consumer product exemption and an SDS is required.

Moving on to the second part of Neal's question, should the PVA be listed in section 3 of the SDS (Composition/information on ingredients) per 29 CFR 1910.1200, Appendix D : http://www.ilpi.com/msds/osha/1910_1200_APP_D.html ?

To be rigorous, we should ask what "substance" means in the context of the HazCom Standard. That's defined as http://www.ilpi.com/msds/osha/1910_1200.html#def_substance 

    "Substance" means chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.

As well as "mixture" http://www.ilpi.com/msds/osha/1910_1200.html#def_mixture :

    "Mixture" means a combination or a solution composed of two or more substances in which they do not react.

So by these definitions, a Tide Pod is a mixture, a mixture of PVA and the solution inside it. Meets all of our General Chemistry definitions of a heterogenous mixture. And the solution inside is indeed hazardous, so it must be listed on the SDS.

But what about the PVA?  First, we perform a hazard classification: http://www.ilpi.com/msds/ref/hazardclassification.html   I found some that declared solid PVA a nuisance dust only, but I did find at several that claimed the material met the requirements to be declared hazardous, which, in turn, requires an SDS: http://www.ampolymer.com/SDS/PolyvinylAlcoholSDS.html  But the key here is the requirements for section 3:

In addition to the information required for substances:
(a) The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards in accordance with paragraph (d) of =A71910.1200 and
(1) Are present above their cut-off/concentration limits; or
(2) Present a health risk below the cut-off/concentration limits.
(b) The concentration (exact percentage) shall be specified unless a trade secret claim is made in accordance with paragraph (i) of =A71910.1200, when there is batch-to-batch variability in the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2) with similar chemical composition. In these cases, concentration ranges may be used.


Note, for the first time, the appearance of the work "risk".  SDS's are generally all about hazard classification. "Hazardous" is an intrinsic property (another Gen Chem definition!) of a material - it does not matter if you have one drop of gasoline or a tanker truck full, gasoline is inherently hazardous. *Risk*, however, is a function of quantity. A tanker truck of gasoline is far more risky than a drop of gasoline. SDS's inform us about hazards so we may then look at the circumstances of use to determine the risks. See http://www.ilpi.com/msds/ref/hazardous.html#hazardRisk (and the links it references under Further Reading) as well as http://www.ilpi.com/msds/faq/partb.html#minquantity for more on this.

So, referring back to the Section 3 requirements w.r.t. PVA, clearly we do not meet point (1). Point 2 asks for a "risk", which I think we can all agree is negligible for this product and its intended use, and it is therefore not necessary to list the PVA on the SDS (which is required for occupational use of Tide pods).

Thanks for the mental exercise.

Rob Toreki

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On Dec 20, 2021, at 1:07 PM, NEAL LANGERMAN <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM> wrote:

All:

No question a manufacturer of a laundry detergent pod must provide a
SDS for the contents. See:
https://content.oppictures.com/Master_Images/Master_PDF_Files/PGC50978
CT_SDS.PDF

The pod itself meets the definition of an "article".
Should the SDS include the polyvinyl alcohol (PVA) pod skin?
If so, what is the exposure anticipated?

Looking forward to the responses.

Neal

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