A4.3.11.4 General statements such as "Toxic" with no supporting data or "Safe if properly used" are
not acceptable as they may be misleading and do not provide a description of health effects. Phrases such as
"not applicable", "not relevant", or leaving blank spaces in the health effects section can lead to confusion
and misunderstanding and should not be used. For health effects where information is not available, this
should be clearly stated. Health effects should be described accurately and relevant distinctions made. For
example, allergic contact dermatitis and irritant contact dermatitis should be distinguished from each other.
And it goes on and on from there. All of the warning phrases are proscribed word-for-word.
And that's just the toxicology data. There are similar requirements for the physical properties.
But you and I, friends, are going to continue to see MSDSs and OSHA SDSs that are just manufacturers' promotional spins on toxicology. You will continue seeing "not listed as a carcinogen by IARC, NTP & OSHA" which really means: "no data available." And "nontoxic" when the product is actually highly toxic but exposure should be within tolerances "when used as directed." As the title of the book written by my friend David Michael (OSHA Director) explains: "Doubt is their Product." And he shows how well this doubt and confusion works for them.
Yesterday, I did an interview for German Radio on the implications of REACH in the current US/EU Free Trade Negotiations. And this issue and the phony US consumer labels which will NOT change with respect to GHS came up. I know damn well, that if I were pitching a WNYC program (I'm a regular there) this subject would be "too deep" and the Producers would have to reject it. How sad for us all.