On Feb 26, 2018, at 11:29 AM, Michael <mabuczynski**At_Symbol_Here**HOTMAIL.COM> wrote:

That is true. If a consumer product is now used in an Industrial setting it falls under OSHA HAZCOM and the SDS is a requirement. The rationale is the frequency of use as well as the concentration. PPE has it place now

Mike

On Feb 26, 2018, at 11:00 AM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:

Let me also correct an assumption made by one of the commenters on this thread that since consumer products come under the CPSC, they could fudge a bit on the SDS.  Not so.  Once that consumer product is brought into a workplace as part of the person's job and will not be used in the amounts or in the ways in which ordinary consumers would be expected to use it, that product comes under OSHA HAZCOM.   And that manufacturer needs to meet all of the same rules for that SDS. The title at the top of the document identifies it as an SDS.

I'm alerting my clients not to accept SDSs for which ACMI simply cites their ASTM D4236 consumer certification instead of dealing with the toxicity issues. WRONG they are -- because ACMI certification is based on consumer use as directed.  Once it gets in a workplace or professional studio all bets are off on how it will be used.  And ACMI KNOWS that most artists do NOT use art materials "as directed." 

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

actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 

-----Original Message-----
From: Hadden, Susan [JRDUS] [JRDUS] <SHADDEN**At_Symbol_Here**ITS.JNJ.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Mon, Feb 26, 2018 9:49 am
Subject: Re: [DCHAS-L] SDS missing ingredients

Monona,

You hit the nail on the head. My experience is in chemical lab support. I didn't realize that consumer products are on the section of the map labeled "here be dragons".

And I, too, consider Sigma Aldrich to be the best out there. Sorry to hear their quality might be compromised by a corporate merger.

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Monona Rossol
Sent: Friday, February 23, 2018 12:57 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [EXTERNAL] Re: [DCHAS-L] SDS missing ingredients

 

Oh my.  Your experience must be with chemicals supplied to chemical labs, because consumer products routinely leave off ingredients from SDS, and a lot of other data, too.  Check out the SDS requirement from OSHA.  They con't even require the 10 tests on section 11 to be reported either with data or the lack of testing.  They recommend it, but don't require it.

 

US SDSs are a mess.  I'm right now doing an evaluation of products for an art conservation project in a major museum.  Those SDSs, both US and Chinese are a disaster. I'm having to go to the same products distributed by Sigma Aldrich to get the straight poop.

 

AND NOW TO A BIG PROBLEM:  The only decent SDSs readily available in the U.S. are from Sigma Aldrich.  But this company is now, as I understand it, Milipore Sigma.  And those Milipore SDSs are NOT good.  If the Sigma Aldrich SDSs go a way, we are going to have to find a better source somewhere.    

 

Anyone else out there notice this?

 

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

actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 

 

-----Original Message-----
From: Hadden, Susan [JRDUS] [JRDUS] <SHADDEN**At_Symbol_Here**ITS.JNJ.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Feb 23, 2018 10:06 am
Subject: [DCHAS-L] SDS missing ingredients

While investigating an incident at my site recently, I came across an interesting issue. Interested in your thoughts.

 

The material involved is a commercially available spray disinfecting cleaner.

 

The container label listed these ingredients:

Active ingredients:

N-alkyl dimethyl benzyl ammonium chloride, 0.1%

N-alkyl dimethyl ethyl benzyl ammonium chloride, 0.1%

Inert ingredients:  98%

 

I pulled the SDS to look for more exposure information. The SDS (updated June 2017) did not list those active ingredients but did list the propellants used and EDTA.  

This is what the SDS says:

 

Chemical Name                                                CAS number       %

Butane                                                                 106-97-8               1-5

Diethylene glycol monobutyl ether            112-34-5               1-5

Propane                                                               74-98-6                 1-5

EDTA                                                                     64-02-8                 1-5

 

Composition comments                US GHS: The exact percentage (concentration) of composition has been withheld as a trade secret in accordance with paragraph (i) of 1910.1200.

 

I took that statement to mean the exact percentage of the ingredients listed were withheld, not that there were other ingredients not listed. It says percentage, not components. Though if you do the math, clearly something is missing from this list.

 

I thought that rather odd so I called tech support of the manufacturer. At first, they were confused as well, then told me that because the active ingredients were EPA registered materials, they did not have to be listed on the SDS. My reaction: Say what???

 

I have seen SDS that said proprietary mixture but still gave you a clue. But I had no idea an SDS could give no indication that there were other ingredients. 

 

No one I have asked at my organization has ever heard of this.

 

Have any of you?  

 

Signed, 

No longer trusting SDS (which I suppose I should know better than to anyway).

 

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