In-Reply-To: <6A844E19-AD60-4DCD-A35E-46D1627ECCC6**At_Symbol_Here**uvm.edu>
Phil,
I appreciate your take on things, and as a chemist that mostly works i
n coordination with the U.S. EPA, I have found MSDSs to be a very valu
able tool, especially when responding to emergencies which require handling
and the wearing of personal protective equipment (PPE). I did n
ot mean to imply that MSDSs fail in some manner or other. They are an excel
lent source of information, however, people need to ensure that they use th
em for the right purpose. Shipping/labeling requirements is defi
nitely not one of them. Most of the problems I have had have been in
the area of neutralization or disposal in which the presence of other
ingredients in small concentrations adversely impacts our actions. I
have been in situations in which we have had what we like to call "undesire
d chemical reactions", also commonly referred to as "uh-ohs", as a result o
f the presence of an ingredient we didn't know about.
One thing I would like to see, and many of my colleagues agree, is mor
e uniformity with regards to the layout of MSDSs. There are content r
equirements, but to my knowledge, no requirement for format.
-------------- Original message from List Moderator <ecgr
ants**At_Symbol_Here**UVM.EDU>: --------------
> From: david.iacovone**At_Symbol_Here**att.
net
> Date: January 15, 2010 2:48:08 PM EST
> Subject: Re: [D
CHAS-L] DOT information from MSDSs
> It has been my experience, spea
king as someone with a hazardous materials and hazardous waste response bac
kground, that whether or not it requires DOT placarding is dependent upon v
olume. Many MSDSs are deficient in this area because some are materials tha
t are usually shipped in small quantities. The DOT guidebook and IATA regs
are better sources for shipping info. Also, Russ is correct in this instanc
e. Don't rely upon MSDSs for shipping requirements. It has also been my exp
erience that manufacturer's don't always tell you everything, especially in
the case of trade name products, unless pressed in
> emergency situ
ations.
>
> ===
> From: "Phil Anderson"
> Date: January 15, 2010 2:33:19 PM EST
>
Subject: RE: [DCHAS-L] DOT information from MSDSs
> As someone who m
ust write MSDS's (as well as do a million other things) I note
> you
r overall displeasure with the MSDS situation.
>
> The MSDS i
s/was meant to provide safety information for the persons who handle a
> chemical, or chemical mixture. Any use of it for other duties is an ex
tention
> of the MSDS beyond where it was originally intended. There
are several layers
> of data that I must absorb and distill and oth
erwise get into the computer
> before I can get it to spit out an MS
D.
>
> If the MSDS were to be a complete manual for the handl
ing of a chemical, this
> would not be enough, but it isn't (probabl
y a Master's or Ph.D may be adequate,
> but also not likely). What a
n MSDS is, is a snapshot of the data and the
> material. It is limit
ed to the available data, and it is always changing. The
> problems
arise when the data is conflicted or old data is viewed with the same
&
gt; "rose colored glasses" that modern researchers seem to enjoy.
>
> Our task, should we be foolish enough to accept it is to be chemis
ts,
> physicians, etc. The best thing we can do is to buy our materi
als (either the
> rarities found in acedemia or the 5000 gallon tank
trucks found in industrial
> use) from the people who provide adequ
ate MSDS's. Look before leaping! And
> when we turn down a supplier
for this reason, tell him! Most chemical suppliers
> in this country
are honest, but generally overworked. If something is wrong on
> hi
s MSDS that causes him to lose sales, most will fix it, IF he is aware of t
he
> discrepancy!
>
> Some of the data desired may not
be reasonably provided on a brief MSDS. Some
> of it may be too new
or too unproven (or even wrong) to be included. Remember-
> these t
hings are NOT peer reviewed papers on the safety that one may want. But
> the writers, in general, should be competent.
>
> A rea
son that I only last year started to include DOT provisions on the MSDS I <
BR>> write, is in anticipation of the adoption of some sort of 15 part f
ormat when
> the US Congress permits it as I am going to retire, pro
bably before this becomes
> a final regulation. The DOT changes thei
r shipping class breakdowns every so
> often, which is why I did not
include them before. I just hope that DOT does
> not change somethi
ng that affects the classing I use now. (As they did about
> 20+ yea
rs ago, when they changed the flash point for Combustible/Flammable from > 100 F. to 140F.)
>
> Had to "rant", sorry!
> > Phil Anderson
> Technical Director
> Aqua Science, Inc
.
>
> ===
> From: "Larry D. McLouth"
> Date: January 15, 2010 12:40:19 PM EST
> Subject: R
e: [DCHAS-L] MSDS source?
>
> Hi Katherine,
>
>
Visit the MSDS HyperGlossary...(use Google search). This has a bunch of fr
ee
> MSDS sites and links to other safety related items, including O
SHA regs and
> proposed standards. I believe this is hosted by the S
afety Emporium which sells
> lab and safety supplies.
>
&
gt; You may be interested in the FAQs - there you'll find a lot of info abo
ut MSDSs,
> the regulatory drives and OSHA interpretations.
>
> Good Luck!
>
> Larry
>
> === > From: harsimran kaur
> Date: January 15, 2
010 12:33:00 PM EST
> Subject: Re: [DCHAS-L] MSDS source?
> <
BR>> Katherine,
>
> In college for chem lab, we were told
to use SRI Hazard MSDS Index and I have
> been using the same ever s
ince. Here's the link:
> http://hazard.com/msds/index.php
> <
BR>> Simran
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