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As author of the most popular Internet site for MSDS information at http://www.ilip.com/msds/index.html I guess I need to chime in on this rapidly diverging thread on a couple of points: 1. 29 CFR 1910.1200 is a performance-based standard. MSDS's have to contain certain information, but there is no required format or ordering. While OSHA now recommends the ANSI format, is examining the Globally Harmonized System and has been accepting public comments on such issues, it will take an act of Congress to make every MSDS have the same information in the same place. And when that happens, let's hope they include CAS numbers, web site addresses and other information that is not currently required. 2. It will take folks like us lobbying their Congressional representatives to enact "plain English" requirements for MSDSs. You would not believe the phone calls and emails I've received on this topic. That is why I created the MSDS HyperGlossary and MS-Demystifier - http://www.ilpi.com/msds/ref/demystify.html And to get an idea of just how many folks don't understand the terms on their MSDS's I'll point out that the MSHG section of our site received over 212,000 page views from 77,000+ unique IP addresses last month. Likewise, according to this OSHA-contracted study http://www.osha-slc.gov/SLTC/hazardcommunications/hc2inf2.html "on average, literate workers only understood about 60% of the health and safety information on the MSDSs associated with the hazardous chemical, in all three comprehensibility studies." 3. The HazCom standard was written so that manufacturers do not have to perform testing on items in order to write the MSDS. For many small companies making simple materials such as window cleaner etc. this works fine because they can rely on an ample body of available data. But when someone makes a new compound that does not meet the "mixture" definition (see http://www.ilpi.com/msds/faq/partc.html#mixtures ) they have no way to determine the toxicity etc. without expensive testing. They have to take their best guess and be overly cautious not just for legal liability, but because they honestly do not know. A plain English requirement for MSDS's would make the manufacturer spell out that no testing has been performed and that the recommendations for PPE etc. they are making are based on similarities to other materials etc. This would go a long way in making the communication of *potential* or *unknown* hazards more accurate. 4. MSDS information is generally inaccurate. The OSHA study I referenced in point 2 stated "one expert panel review established that only 11% of the MSDSs were found to be accurate in all of the following four areas: health effects, first aid, personal protective equipment, and exposure limits. Further, the health effects data on the MSDSs frequently are incomplete and the chronic data are often incorrect or less complete than the acute data." Yes, that's ELEVEN percent. You can start a whole new thread on how to improve this number and the study provides a lot of food for thought. 5. If our thousands of daily visitors could rewrite HazCom in one way, it would be to *require* manufacturers to post all their MSDS's on their web sites. There has long been a call for a "national MSDS repository", an idea that OSHA examined and discarded years ago; this gap is certainly being filled by private industry, although it does nothing for an employee whose employer does not subscribe to an MSDS service. 6. MSDS's are not required for materials that do not meet the OSHA definition of hazardous, http://www.ilpi.com/msds/ref/hazardous.html While almost anything can meet that minimum definition, companies persist (usually because of downstream customer demands) in putting out sheets for non-hazardous materials instead of simply supplying a letter that they have determined under 29 CFR 1910.1200 that the material is not hazardous and, therefore, no MSDS is required. OSHA discourages MSDS's for non-hazardous materials but can not prevent it. In response to a comment today, At 11:07 AM -0400 9/10/04, Phil Anderson wrote: >It simply is not reasonable to try to tell everyone in the world what is >in everything in the world. The problem comes when we add in consumer >items, all of which are not even covered by the MSDS section of the OSHA >laws. (OSHA covers only non-consumer chemicals used by employees). Just a fine point here - consumer items used in a non-consumer fashion *do* require an MSDS. For example, an office worker who uses Windex with the same frequency and duration as a consumer does not need an MSDS. But a window washer who uses the stuff all day does require one. It would be terrific if the top of every MSDS had a statement to the effect "This information is meant for employees who may be exposed to this material as part of their job duties or in the event of an emergency in their workplace. It is not meant for household consumers who use this substance on an occasional basis." Rob -- ===================================================== Safety Emporium - Lab & Safety Supplies featuring brand names you know and trust. Visit us at http://www.SafetyEmporium.com esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412 Fax: (859) 523-0606, 4905 Waynes Blvd, Lexington, KY 40513-1469
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