1. Now that we can easily search aggregated sources of information (see Ralph, below) and the hazard classifications appear in sheets in a standardized place and format, we can immediately see these contradictions that would have formerly required extensive searching and comparison by hand.2. One would think that as the Appendix A of 29 CFR 1910.1200, the OSHA HazCom Standard provides a much better "flow chart" and standardized approach to the classification process (formerly called hazard determination) that the quality of the assessment would improve. While parts of that are straightforward, others are mind-numbingly complex. I invite you to look here http://www.ilpi.com/msds/osha/1910_1200_APP_A.html#A.1.3 and here http://www.ilpi.com/msds/osha/1910_1200_APP_A.html#A.1.3 as two examples and put yourself in the perspective of perhaps a B.S. chemist or staff member at a small chemical company.
While we would like to think that the major companies have staff on hand that can comprehend and make prudent professional assessments to arrive at similar conclusions, remember that not everyone starts with the same data set and not all companies have the same priorities. And, at other companies, no such in-house expertise exists. Some will outsource the task to consultants or firms with varying levels of expertise and others will try to figure it out on their own. The result is wildly differing classifications even though the rule book is the same for everyone.
I'm hoping someone can tell my why, after we finally have a good system of describing acute and chronic toxicity with the GHS dose-response Categories, I'm suddenly seeing the misleading dumb old HMIS one number toxicity system showing up even on the new Sigma SDS for Cyrene.
On Jun 10, 2019, at 7:22 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:
This is an interesting point. The PubChem Lab Chemical Safety Summary for calcium nitrateToday, I unboxed a new chemical and noticed that it did not have all the required GHS pictographs on it. The substance was calcium nitrate ... no oxidizer symbol.
https://pubchem.ncbi.nlm.nih.gov/compound/24963#datasheet=LCSS =A7ion=GHS-Classification
lets us know that there is significant disagreement within the European Chemicals Agency (ECHA). Only irritant is assigned by more than 60% of the notifications on this chemical:
- Aggregated GHS information provided by 718 companies from 25 notifications to the ECHA C&L Inventory. Each notification may be associated with multiple companies.
- Reported as not meeting GHS hazard criteria by 4 of 718 companies. For more detailed information, please visit ECHA C&L website
- Of the 24 notification(s) provided by 714 of 718 companies with hazard statement code(s):
- H271 (10.36%): May cause fire or explosion; strong Oxidizer [Danger Oxidizing liquids; Oxidizing solids]
- H272 (27.03%): May intensify fire; oxidizer [Danger Oxidizing liquids; Oxidizing solids]
- H302 (34.31%): Harmful if swallowed [Warning Acute toxicity, oral]
- H315 (62.61%): Causes skin irritation [Warning Skin corrosion/irritation]
- H318 (24.65%): Causes serious eye damage [Danger Serious eye damage/eye irritation]
- H319 (66.11%): Causes serious eye irritation [Warning Serious eye damage/eye irritation]
Information may vary between notifications depending on impurities, additives, and other factors. The percentage value in parenthesis indicates the notified classification ratio from companies that provide hazard codes. Only hazard codes with percentage values above 10% are shown.
Thanks for pointing this out.
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
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