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Monona--
While you make several very good points about isocyanates, and I am not
familiar with this particular product, I believe you do those who write
MSDS's a great disservice, and your advice could in fact dissuade people
from reading the MSDS or warning labels. ("MR: If you get your hazard
data from the people selling the product, then I have a car I want to
talk to you about.") Why bother reading it if "THEY" are just going to
lie about it?
In a former life, I managed an EH&S group for a Fortune 500 company.
My regulatory group, and our legal department, were never hesitant about
disclosing hazards. Even the business people understood the necessity.
CIH's and CSP's, along with toxicologists and those who understand OSHA
Hazcom, are well aware of their responsibilities, and in industrial
meetings I never found anyone from a good-sized company who did not take
this responsibility very seriously.
It would be much more productive for 'MRSAFETY MAN' to contact Dow
again, and ask to speak with their regulatory specialist for this
product. When he has that person on the line, he should explain some of
the excellent technical points you raise below, and ask if perhaps the
industrial hygienist who is responsible for the Dow workers who produce
this material could be in a conference call. I don't know why Dow did
not highlight the isocyanate issue--it can be a problem for asthmatics
as well as those who develop a sensitivity--and the weird thing about
isocyanates is that at least some of them can cause respiratory
sensitivity through SKIN contact. In my experience, Dow takes good
care of its workers (I did work for them as a student intern 20 years
ago, but not since) and they may have data that led them to write the
MSDS and label as they did. If MrSafetyMan doesn't ask, he is going on
incomplete information.
Also, if you create a new molecule for commerical (as opposed to
drug/food/cosmetic use) it is NOT unregulated---EPA has a
premanufacturing review process. They can stipulate all sorts of
warnings on labels/restrictions on consumer use, etc. as a condition of
approval.
My 2 cents' worth, and this is only my personal opinion, not that of my
employer or any organization to which I belong.
Margaret
Margaret A. Rakas, Ph.D.
Manager, Inventory & Regulatory Affairs
Clark Science Center
Smith College
Northampton, MA. 01063
p: 413-585-3877
f: 413-585-3786
>>> 09/09/04 01:41PM >>>
MR: I'll answer in the body of your e-mail:
In a message dated 9/8/04 9:09:50 PM Eastern Daylight Time,
mrsafetyman**At_Symbol_Here**juno.com writes:
> Wow, thanks for the input. The product does have a rather low health
hazard
>
MR: There are two types of Great Stuff Products. The first type is
the
Great Stuff which says on the can it is for "household use." The other
spray can
products are Great Stuff Gaps and Cracks, Great Stuff Window Seal,
etc.
And all of these are available at good hardware outlets that
contractors use.
Great Stuff Gaps and Cracks contains between 5 and 30% (this alone is
a
worry) a polymethylene polyphenyl isocyanate CAS # 9016-87-9, that
contains 40-50%
4,4'methylene bisphenyl isocyanate CAS# 101-68-8 (MDI).
This means that somewhere between 2% and 15% of the product is MDI with
a
TLV-TWA of 0.005 ppm, Recommendations for air-supplied respirators are
on the
MSDS because there is no cartridge approved for it without change out
schedules
and air monitoring.
I searched and searched the Dow site and it apparently does not provide
the
MSDS for the household variety. But according to the National
Institutes of
Health National Library of Medicine's Household Product Database, the
prepolymer
is the primary ingredient and only 0.2-0.05% is in the form of MDI.
But
other countries recognize that the prepolymer is just as toxic as MDI,
it just has
a lower vapor pressure so exposure should be lower. In England, for
example, the occupational exposure to this product would be regulated
by the number
of isocyanate units on the compound, not the compound to which the
units are
attached.
In the US, if you change the structure of the compound, it is now
unregulated
and can be labeled without warnings or even "nontoxic" if you choose.
This
is nuts. But it can explain why a product that contains reactive
isocyanate
structures has a low toxicity rating.
and it is used by three labs I know of to seal bottles as well as
many
contractors. I
> have not heard of an incident yet until now.
MR: You won't. Most people use the stuff for a while with no
difficulties.
It is the people who become sensitized whose lives are ruined or who
die.
Read about the isocyanates. They are powerful sensitizers and
irritants. Some
cause cancer, so the effects will not be seen immediately.
> contacted Dow and they advised that the product is safe if used
> correctly.
MR: If you get your hazard data from the people selling the product,
then I
have a car I want to talk to you about.
They have not had any recent litigation as of yet mentioning your
incidents.
MR: The workers' comp cases involve the employer, not Dow. And do you
really
think Dow would tell you about any lawsuits pending or settled?
Why don't you provide me your snail mail address and I'll send you a
long
data sheet on the urethanes which mentions some of the incidents of
which I am
personally aware as a union rep and expert witness.
> direct me to actual other data or events that are documented since
> this is very enlightening to me. I inspect many facilities as a code
> enforcement officer and that is how I saw the processes of corking
during a fire
> inspection. If i had some hard data, this would enable me to approach
those i
> know that perform this work.
> Thanks for your assistance and input.
MR: This is not a mystery--it is a well known problem. How else
could the
ACGIH set a 0.005 ppm TLV-TWA for MDI? They have to have a PILE of
data to
set a low TLV or the affected industries will sue them for restriction
of trade.
Ah, that's the answer to your questions. Get a copy of the ACGIH
Documentation of TLVs for MDI. That will put it all in perspective for
you better than
my data. All the data and references are there.
Monona Rossol, M.S., M.F.A.,
industrial hygienist
Arts, Crafts & Theater Safety, Inc.
and
Safety Officer,
United Scenic Artist's, Local 829
International Alliance of Theatrical Stage Employes (IATSE)
181 Thompson St., #23
New York NY 10012-2586 212/777-0062
artscraftstheatersafety.org
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