Michael,
I may or may not concur with your response. Please let me re-state your perspective to make sure I understand your comment. Please correct me if I am wrong.
If you are not authoring enough SDSs to obtain/maintain proficiency, you should be relying upon vendors/contractors to perform the function.
If routinely authoring SDSs or developing SDSs become a primary job responsibility then proficiency is required.
The statement “authoring properly and with success” is the area I disagree with.
Shouldn’t we be able to interpret SDSs received to determine adequacy?
Today I received an SDS from a reputable manufacturer, upon review the SDS was inadequate and required me to re-evaluate my chemical exposure risk assessment, PPE required, etc.
The 1984 OSHA HazCom Standard did not prescribe proficiency or professionally adequate SDS authoring. Anyone else remember how MSDSs were initially received? Initially, they included proper PPE protection, hazardous waste classifications, etc., but ended up being covered by generic statements with legal disclaimers, such as “Use adequate PPE”, “dispose of in accordance with federal, state or local regulations,” etc.?
I believe the OSHA GHS standard will result in some manufacturer/employer being investigated, cited, etc., for exposing personnel to “recognized hazards”.
My question is what sources were used, how were the risks evaluated, what are the scientific validity of the recommendations? How was your assessment documented? Can the assessment be justified in a court of law?
We may be missing the task required to be accomplished. Is the task to author a SDS or protect employees/downstream users? My question is if you are an EHS Professional, are you going to rely upon a vendor/contractor to interpret that information for you while assuming the liability or allow them to perform the authoring while providing oversite/evaluation? Will your employer/owner be satisfied with “I hired a reputable firm to author the SDS?”
I would propose defining the learning track, defining success and stressing the ethical issue of performing those tasks within your areas of expertise as key components.
Using contractors to author SDSs, regardless of qualifications, does not obfuscate our oversight responsibilities or liabilities. I respect the feedback received from this list and would appreciate any other thoughts or opinions, since this is my opinion only.
Thank you,
BruceV
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Michael
Sent: Monday, May 1, 2017 9:26 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Help in preparing SDS's
"One SCHC course does not a SDS author make". The SCHC is the best Haz Com professional association there is and they have a very diverse series of related courses to help the HC professional become professional. If this is a one of SDS request then contact the vendors /consultants mentioned in these messages and get your SDS created for a few hundred dollars. If this area is becoming a job responsibility then join the SCHC and get on track for learning about all of the necessary area needed to perform this authoring properly and with success.
Mike
Although it is not yet posted on the web, SCHC will be offering a SDS course in September 2017, U.S. Hazard Communication for Workplace Chemical Products (HCS 2012) - Overview of Requirements and Practical Examples in SDS and Label Preparation.
http://www.schc.org/u-s-hazcom-for-workplace-chemicals
Society for Chemical Hazard Communication Professional Development Training U.S. Hazard Communication for Workplace Chemical Products (HCS 2012) Overview of .... |
Michele Sullivan
You may want to contact the Society for Chemical Hazard Communication (SCHC)...when I wrote MSDS's during the Dark Ages (1990's) they were a fabulous resource and they are still in existence, I checked...
On Sun, Apr 30, 2017 at 1:20 PM, Jack Armstrong <jack**At_Symbol_Here**azsafety.com> wrote:
I have a client who is developing a new product and hoping to have one of their Lab technicians develop the SAS required for this product.
Can anyone recommend a training program that will provide the necessary skills for preparing an SDS?
--- For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--
Margaret A. Rakas, Ph.D.
Manager, Inventory & Regulatory Affairs
Clark Science Center
413-585-3877 (p)
--- For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
