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Previous by Date: Subject: Re: [DCHAS-L] Online SDS subscription and emergencies Date: Friday, April 25, 2014 8:45:05 PM Author: Peter Zavon <pzavon**At_Symbol_Here**rochester.rr.com> |
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Thanks for the opportunity to take my comments to the next level and explain what I mean. My posts are long enough, so I didn't go into this completely.
Since I'm probably the only member of the group who was one of the activists responsible for getting an amendment to the Federal Hazardous Substance Act passed that affected the labeling of art materials passed in 1988 and which was later applied to the chronic hazard labeling of all consumer products, I am very aware that it is the US Consumer Product Safety Commission that has the authority over consumer product labeling though the FHSA.
When I say the "US exempted consumer products," I was referring not to OSHA but to both agencies. It was not OSHA that exempted them. Our US Consumer Product Safety Commission, chose not to adopt it. As a result, as long as a product is made in the US and sold in the US, the same crap labeling will be used. If the consumer product is also exported, then it will have to have proper GHS shipping labels and an SDS.
CPSC has no authority to require SDS. OSHA had the authority to require first MSDSs and now has the authority to require SDSs on all potentially toxic consumer products that are used in the workplace. This also applies to products under other agencies (e.g., FDA cosmetics, drugs or ATF explosives) used in the workplace as well. OSHA has that authority, but has never exerted that authority over any consumer manufacturer to my knowledge. And remember, I read the Federal Register in hard copy every day and have since 1977. I think I would have seen that item and written on it with glee!.
Since there is no enforcement on consumer products manufacturers other than pressure from customers and/or employers demanding MSDSs to meet their HAZCOM regs, consumer product MSDSs have been grotesquely inadequate. For art materials in particular, the MSDSs only references ASTM D 4236 without any further information on ingredients, even if regulated substances are present. And I fully expect to see the same practice with the SDSs. As a result, I have called for repeal of the law I helped to pass because it has been completely misused.
And don't waste your time hoping that "eventually" the CPSC "will implement some version of GHS within the scope of authority and thereby bring some or all consumer products under some form of GHS.." Ain't happn'.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
-----Original Message-----
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Apr 25, 2014 9:55 pm
Subject: Re: [DCHAS-L] Online SDS subscription and emergencies
I generally find Monona's contributions to be useful and on point, but I am getting a bit tired of her claim that the US implementation of GHS "exempts consumer products." What we have at present is only the OSHA implementation of GHS, and OSHA has no authority to require anything with regard to consumer products, just as it has no authority over the information in Section 14 on Transportation or over the environmental sections. Eventually, one can hope the US agency with authority over consumer products, the Consumer Product Safety Commission, will implement some version of GHS within its scope of authority and thereby bring some or all consumer products under some form of the GHS. Until then it is not that the US exempts consumer products from GHS, but that the US has not moved one way or another on that topic.
Would it be better if the US implementation of GHS had been more like the EU in being an across-the-board process? Perhaps. But it wasn=E2=80™t and the structure of our regulatory system made that almost certain from long before the GHS was at a stage where it could be implemented by anyone.
So continue to advocate for CPSC to move forward, but let's recognize what is and is not possible for OSHA to do in this area.
Peter Zavon, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: Friday, April 25, 2014 8:26 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Online SDS subscription and emergencies
And the US OSHA chose not to comply with most of section 11 on toxicology. You need to go to companies that export or score an EU SDS on the same chemical to find out which of the 10 toxicology/environmental tests have actually been done. And if WorkSafe Canada does what they say they intend to do--which is to refuse to "harmonize" with the US, they will do Section 11 right, will retain the requirement to identify carcinogens, mutagens and teratogens in amounts greater than 1% (which we have dropped) and will not exempt consumer products as we have. The Australian SDSs also require identification of carcinogens, sensitizers and teratogens whether or not they are trade secrets.
One by one, it is other countries that will raise the level of worker protection and information. We certainly will not and we put pressure on these countries not to raise their standards.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
-----Original Message-----
From: Bruce Van Scoy <brucev**At_Symbol_Here**BRIGHT..NET>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Thu, Apr 24, 2014 7:22 pm
Subject: Re: [DCHAS-L] Online SDS subscription and emergencies
James,
Your right that MSDS's significantly lack in quality, especially for everything that we need to look for and SDS's are standardized - regarding format, but watch out for the country of origin for the chemical. Each country can decide which sections of the GHS standard that they will adhere to.
Just a word of caution, nothing replaces due diligence,
BruceV
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of James Saccardo
Sent: Wednesday, April 23, 2014 10:32 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Online SDS subscription and emergencies
MSDS's leave a bad taste in my mouth, but I am not going to turn away from a tool that can only increase safety performance. I embrace them for they are a good starting point. I do not dispute that an MSDS, or today an SDS, is a useful tool (especially for the blue collar worker). Sometimes you can even get the flashpoint or autoignition temp or the DOT designations, but I have found inconsistencies and errors over the years. I have also seen MSDS's fail to mention that a substance is listed as a 2B carcinogen. Ask yourself how many times have you had to seek other data after reading the SDS (i.e. HSDB, Toxnet, IRIS, NTP, ACGIH, RTECS, NIOSH, ATSDR, Merck, a peer reviewed article, or some other source). They are often anemic and vague with repetitive catch phrases (i.e. follow all Federal, State and local regulations, Use appropriate personal protective equipment, not fully investigated, etc.). Like many written plans, the SDS is just a document to meet the requirements of the law.
Honestly, I think that the SDS's should be prepared by a single agency and not the manufacturers attorneys. This would make sense, but who would bear that burden? (Perhaps the World Health Organization). At least the SDS has now been standardized. Further, the SDS is for the most part are for the pure substances and when they are for a mixture the proprietary thing gets in the way. I have signed many consent decrees to get the exact ingredients and concentrations of formulations on the basis of exposure and waste determination needs. But as always, I find myself searching the literature for further information - ok, i'm done venting, let me get to the point =E2=80=A6
I think that the electronic SDS software is great If it makes laboratory staff use them, and if it works with you inventory program it seems like a no brainer. You should ask -
Are the employees making good use of the inventory program?
Are employees more likely to refer to SDS's and use them more often in electronic format as opposed to hard copy?
What are the problems with your current hard copy system?
Will they have better access to SDS's (i.e. via their "device")?
Are there connectivity issues (i.e. rural areas) ?
Can you track the usage by the users?
Do you have emergency generators?
For the emergency situations short of apocalypse - If there is a command center with back-up power then what is the problem with on line system? -nothing! If the critical network systems are down ( satellites, gas, water, electricity), then I think the last thing anyone will be looking for is an SDS. The spirit of the law is that employees have basic right to know the hazards in the workplace, which is how the SDS is to be used. I think that many misinterpret the need for SDS's in emergency situations. For that, inventory lists with haz mat categories and locations form your inventory program would probably be of more useful. I think that it is neat your area supervisors bring an SDS binder to the emergency assembly point or emergency room (has a physician ever look at the binder, they use NIH/NLM HSDB).
Lastly, does anyone know of anyone getting cited for not having an MSDS or SDS? I'd love to know if anyone is on record for failure to maintain MSDS=E2=80™s? ever been fined? or any injury or illness blamed on a lack of MSDS?
Good luck in whatever decision you make. If your institution can afford to pay for the access, it certainly worth prototyping it for a period of time and then evaluating the effectiveness.
Just my $0.02
Be Well,
James Saccardo, CHMM
From: DCHAS-L Discussion List [dchas-l**At_Symbol_Here**MED.CORNELL.EDU] on behalf of Jeffrey Lewin [jclewin**At_Symbol_Here**MTU.EDU]
Sent: Wednesday, April 23, 2014 9:37 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Online SDS subscription and emergencies
I'm at Dr. Crowl's University. I was a member of the selection and later the implementation committee for MSDS-online for the University. Al (our OSHS and dchas member) can expand on this but MSDS-online is available on any computer, anyplace including off campus, but it is protected behind our University login system. That includes smart phones and we even post QR codes on lab doors with direct access to the link, although if you use a "tough" password it is a bit of pain to login (upper case, special characters, etc. require a bit of manipulation and you don't have that finger muscle memory to type it out). But, I have direct confirmation that it acceptable to inspectors - during a recent MIOSHA inspection I was asked to produce an MSDS (pre-SDS) for a chemical, I used my smartphone and he accepted it (I did have to "prove" I was using MSDS-online, not Google, by showing him the log in). BTW, as a back up there is also a "fax back" option if you want to call and have a specific MSDS faxed to you.
Jeff Lewin
Biological Sciences
Michigan Tech University
On Wed, Apr 23, 2014 at 5:24 PM, Daniel Crowl <crowl**At_Symbol_Here**mtu.edu> wrote:
I believe the OSHA lab standard requires that the MSDS's be available at all times within the laboratory. Not down the hall or in another room.
With on-line access to an MSDS library, I'm not sure if this has all been settled with OSHA.
Technically, if you have a computer in the lab with internet access 100% of the time this should be OK. Not clear how this will work in an emergency.
My university has an online service, but I still prefer hard copy in my lab. I only have a dozen chemicals so it is no big deal.
Maybe others will have more information.
Dan
On Wed, Apr 23, 2014 at 1:16 PM, Suzy Arnette <suzyarnette**At_Symbol_Here**boisestate.edu> wrote:
Good afternoon,
We are looking to get a subscription to MSDSOnline that links in with our inventory software. All of a sudden we are getting a lot of questions about what people should do in an emergency. They have been trained to grab their MSDS binder and go to the emergency room, etc. and the idea of not having something tangible is worrying a lot of people.
Have any of you dealt with this issue? How have you talked your customers down and encouraged them to embrace the new system? How do you handle emergencies and accessing MSDSOnline remotely?
Thanks so much,
Suzy
--
Suzy Arnette, PhD
Lab Safety Officer
Radiation Safety Officer
Boise State University
Environmental Health, Safety, and Sustainability
Phone: 208.426.3906
MS-1826
http://operations.boisestate.edu/EHS
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