I hate the way OSHA wrote that. It gives manufacturers the worst out possible. They never discuss the "used as directed" issue. So I prefer dealing with companies that provide SDSs on deionized water.
This omission is egregious in the art materials industry in particular.. There is a separate labeling law in the FHSA and in the Consumer Regs for art materials that require a Board Certified Toxicologist to make the assessment. These docs are paid either directly or indirectly through a trade association for this work. So the more often the toxicologist's opinion is what the manufacturer wants to hear, the more likely they are to get business.
That results in art materials that are not only not required to have an SDS, they are labeled "nontoxic" when they contain substances that are known to be toxic in larger amounts than they anticipate or which are untested for toxicity but likely to be toxic based on class (e.g., benzidine pigments that have never actually been tested, anthraquinone pigments related to IARC 2B anthraquinones, etc. etc.). Almost none of the ingredients have been tested for the ability to sensitize either.
The other problem is I have never met a teacher or artist who uses art materials only as directed. They experiment creatively. They work in their kitchens and bedrooms. They heat, sand, apply the materials to food surfaces, and do all manner of things that were not anticipated in the assessment.
I think that whatever the consumer product or art material is, teachers, parents and artist should have access to the list of actual ingredients.
That said, back to molasses. I've tasted molasses. As far as I'm concerned it is toxic.
Monona
-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, Aug 21, 2020 3:31 pm
Subject: Re: [DCHAS-L] New Video Series | ACS Matters | August 18, 2020
Just to be clear: OSHA does NOT require an SDS for a material that, after performing the required hazard classification, is found to be non-hazardous. See the SDS FAQ at
http://ilpi.com/msds/faq/partb..html#nonhazardous and the links therein for a short discussion.
Just to stir the pot, there is something to be said in the molasses discussion about universal precautions, the shortcomings of risk assessments, and reinforcing safety habits. But I=E2=80™ll let someone else say it (wink).
Rob Toreki
======================================================
Safety Emporium - Lab & Safety Supplies featuring brand names
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
As has been mentioned before, context matters. Perhaps, as Marta=E2=80™s colleague said, there was a better thumbnail that would have conveyed how engaging this video series is without prompting safety questions when removed from the context of the presentation.
As for the idea that safety glasses are warranted when pouring molasses from a glass beaker, I'm going to have to disagree. While the SDS for molasses that John shared does call for eye and hand protection, Section 2 of that document states that molasses is non-hazardous. Manufacturers that recommend PPE for handling non-hazardous substances may be motivated more by liability fears than by reasoned risk assessments. And, while I can=E2=80™t claim that Jim's scenario is impossible, it doesn't seem any more likely than getting glass in one's eye while washing dishes after dinner.
Chris
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Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer
