An unexpected but clear benefit of the web-based MSDS exercise is that students saw firsthand the shortcoming of an MSDS. This is an important lesson. Consistent with the scientific and Socratic methods, we do not want students to believe everything they read, even if it is published in a scientific journal. Healthy skepticism is even more important when students seek information from non-peer-reviewed resources like the Internet (in chemistry or any other topic, for that matter). In fact, a wily instructor might deliberately create an assignment in which two "authoritative" resources conflict.
Seeing that two MSDS sheets from the same reputable manufacturer had contradictory first aid instructions depending on the concentration led to some very interesting discussion. In fact, this question was rephrased and sent to the ACS Division of Chemical Health and Safety's (DCHAS) listserver. It was noted that the MSDS for solid potassium permanganate states not to induce vomiting while that for 0.1N says to induce vomiting. So, if one purchases a solid and makes a 0.1 N solution, what MSDS should you keep on file or refer to in an emergency? Even the members of the DCHAS discussion list could not come to a consensus!
Which is what the other folks were saying.h. Cut-off values/concentration limits.• The HCS 2012 classification approach does not have one single cut-off value for classification. Each physical or health hazard has its own specified cut-off values for each specific category. See Appendices A and B of the standard for each specific cut-off value. A partial list of cut-off values can be found in Appendix B of this Instruction.• Under the HCS 1994, a product, if not tested as a whole, that contained 1% of a hazardous component and 99% of a nonhazardous ingredient, was assumed to present the same hazard as the component. This may not be the case under HCS 2012.• To classify the hazards of a mixture, the manufacturer or importer must use the information contained in Appendices A and B of the standard. This may possibly result in the chemical having a different classification than was previously identified under HCS 1994.
On Feb 2, 2017, at 8:17 AM, Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM> wrote:Aniello:The short answer is, "Yes, it is incorrect to provide an SDS that is not reflective of the stuff in the bottle." 29CFR1910.1200(g)(5) states in part:"The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification."There are a boatload of regulations contained in Appendices A and B of the Hazard Communication Standard and in the GHS "Purple Book" on how to determine the classification of the material. Appendix C of HAZCOM gives the required label hazard and precautionary statements as well as the required pictograms for the SDS.Harry--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.orgOn Wed, Feb 1, 2017 at 6:15 PM, Tambasco, Aniello <aniello.tambasco**At_Symbol_Here**wilkes.edu> wrote:Hi---- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.orgPlease let me start to wish Monna Happy Birthday!!!!My concern is the following. We run a Chemistry Outreach program to local high schools.We provide some different types of equipment and small quantities of chemical solutions to these sites. I was questioned today by an individual that came from industry and now is working in academia. The concern was that the SDS should reflect not only the chemical but the form it is in. For example, I prepared a 0.1M Magnesium Sulfate solution. I usually provide an SDS of Magnesium sulfate heptahydrate solid and not of the solution I prepared. Is that wrong? I researched OSHA and did not see anything in the language? Is there anything in the new GHS system? I could not find anything. I appreciate everyone's help and input.Thanks,Aniello TambascoLab Tech. & AssistantWilkes University Chemistry Dept.--+++++++
Harry J. Elston, Ph.D., CIH
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