Since the advent of the GHS SDS system, I have learned more in the past few years about using and developing SDS' than I thought possible, but would like to
address some of your comments, from a manufacturing safety professional, and also assist in creating information for our own product SDS:
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Size of spill; it really is incumbent upon the end user to do additional research and know their processes, facilities and abilities of employees as
to their response. The uses of chemical, i.e. sulfuric acid seems to be infinite, so it is quite impossible to address each various scenarios. The end user had do the research.
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As for PPE again you have to research the capabilities of the gloves you purchase as to material, thickness, durability and suitability for the work
or exposure you anticipate. This information is readily available from the PPE manufacturers and if it isn't find a different brand that has the data.
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SDS' are or can be scarey. I asked my lawn service company for SDS for the products they put on my yard. You would think every squirrel and stray critter
in our neighborhood would be dead, but they still thrive.
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Developing SDS is a field by itself, as we use a CIH whose firm specializes in developing SDS for companies.
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These are legal documents, so if a company makes a specific statement and it goes upside down, they would be liable. So again, the end user has responsibilities
to do their own research, hire specialist to assist them and keep their people and local environment safe.
Santa can't help us, and government agencies walk a political tight rope.
The good news is that SDS since the change in regulations are much better than the old MSDS in almost all the hundreds of products I have SDS on file.
Good questions but no profound answers!
Harold
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of Ben Ruekberg
Sent: Wednesday, January 8, 2020 11:57 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Good idea or maybe not for SDSs
Hello and Happy New Year,
Imperfect as they may be, we rely on SDSs for guidance in dealing with chemicals.
For student laboratories, problems arise that are different from industrial scale problems. SDSs seem to be concerned with the industrial scale. Take for examples, what to do in case of a spill. Would it not
be helpful if SDSs were to designate size-appropriate actions? It seems to me that, generally speaking, spilling a milliliter of sulfuric acid should require a different response from that for the spill of a tank car full of sulfuric acid. Well-meaning teaching
assistants, who do not have instructions on what action to take depending on the size of a spill, will tend to act on the side of caution (we would hope) which may involve unnecessary expense and disruption. Would there not seem to be practical value in
an SDS saying something along the lines of "This amount is a small spill and you should do this, that amount is a medium spill and you should do that, more than this sized spill means you should evacuate and call 911!"? Clearly, what constitutes the various
categories of spill size differs from substance to substance, which is why the SDS would seem (to me) the appropriate place for this information. There might even be the benefit of making some SDSs less scary.
This might be asking a bit much from documents that say to wear appropriate gloves without saying which gloves are appropriate. Should I just put this in my next letter to Santa?
Thank you very much,
Ben
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