Dear Aniello,

The SDS for a chemical in different form should be different. According the 6th edition of GHS Purple Book, there are 17 hazard classes under the physical hazards (previously only 16 hazard classes). If a chemical is in solid form, then when preparing the SDS, those physical hazards that are not related to solid form will not be considered when assessing the physical hazard, for example, flammable liquid will be 'not applicable' in this context.

Furthermore, by referring to the definition of 'substance' and 'mixture' in GHS Purple Book, you might want to consider the chemical solution as 'mixture' instead of 'substance'. Hence some of the formula - e.g. additivity formula under the acute toxicity in health hazards might apply.

Just my 2 cents opinions :)

Best regards,

Goh

On Fri, Feb 3, 2017 at 12:47 AM, Melissa Anderson <mwanderson08**At_Symbol_Here**gmail.com> wrote:

Thanks Harry, this looks to keep me busy for a while. :)

On Thu, Feb 2, 2017 at 8:11 AM, Harry Elston <helston**At_Symbol_Here**midwestchemsafety.com> wrote:

Melissa:

The 644 pages of pure excitement from ECHAS provides CLP guidance galore: https://echa.europa.eu/documents/10162/13562/clp_en.pdf

H

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Melissa Anderson
Sent: Thursday, February 02, 2017 9:41 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] SDS concern

On a related note to this question- what's the best approach for determining the effect of modifications (i.e. dilution) to materials from the original SDS form? I don't have to do any official documentation, but I'm curious how to best approach this kind of situation for internal risk assessment.

Melissa Anderson

Chemistry Instructor

Pasadena City College

On Thu, Feb 2, 2017 at 5:17 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

On Wed, Feb 1, 2017 at 6:15 PM, Tambasco, Aniello <aniello.tambasco**At_Symbol_Here**wilkes.edu> wrote:

Hi-

Please 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 Tambasco

Lab Tech. & Assistant

Wilkes University Chemistry Dept.

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Harry J. Elston, Ph.D., CIH
Principal
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Twitter: **At_Symbol_Here**MidwestChemSafe

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Best regards,

Goh Choo Ta, PhD

Senior Lecturer / Research Fellow

(Chemical Governance and Chemical Safety)

&

Head of Quality Assurance

Institute for Environment and Development (LESTARI)

Universiti Kebangsaan Malaysia (UKM, National University of Malaysia)
Tel: +603 8921 7634

Fax: +603 8925 5104
Email: gohchoota**At_Symbol_Here**ukm.edu.my, gohchoota**At_Symbol_Here**yahoo.com

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