Everyone,

This is a very interesting and some what heated discussion on SDSs. As someone who has authored SDSs for a chemical company I figured I would provide some information that I think people do not know about. First, in present day SDS authors tend to use software that populates an SDS document based on information the author enters. For example for a registered compound I would enter a CAS# and the software pulls in information from various sources, such as TSCA and REACH. Obviously as the author there is some editing power to change based on internal data, customer needs, etc. For new, novel compounds the author has less resources to pull from. Often you look at reagents used to make a product (especially for mixtures) or look at similar compounds and what data is available for them. In theory a compound would go through rigorous testing to be classified, however, test that meet GHS standard are expensive and often not required by TSCA in order to be registered and sold. Also many of the Health Hazard type test are done on animals which opens up a whole new set of arguments. If a company does have a material tested they are not required to share that information or even publish it on their SDS. EU REACH is somewhat more stringent with requirements when registering new chemical products but US SDSs don't often pull in data from ECHA. This all can seem very frustrating, especially to the EHS community, but there is a lot of money involved in these classifications, not just in testing, and until there is a more regulations and standardization it won't quickly change.

Sara Johnson, Ph.D., CCHO

Chemical Hygiene Manager

UNC Chapel Hill Environment, Health & Safety/Risk Management

On Wed, May 26, 2021 at 1:51 PM Kolodziej, Christopher <ckolodziej**At_Symbol_Here**ehs.ucla.edu> wrote:

Tammy,

Good luck getting anything useful out of Sigma. A few years back I was trying to get some clarity from them regarding the classification of tri-n-butylphosphine. According to literature, it has an autoignition temperature of 390 F, but was being classified as pyrophoric. Sigma responded with an updated SDS that replaced the autoignition data with the statement "The substance or mixture is pyrophoric with the category 1."

As an interesting side note, their updated SDS did still provide both oral and dermal LD50 values. I can't recall ever seeing those data points being reported for a material that's truly pyrophoric (nor would I expect to, given the obvious practical and ethical challenges with trying to determine those).

Chris

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

Mobile: (310) 261-8611

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Tammy M. Lutz-Rechtin
Sent: Tuesday, May 25, 2021 7:22 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.

.Thank you to Leah and everyone for your helpful responses.

Sources of data can sometimes be difficult to find for certain. PubChem is generally a great resource.

To add fuel to this discussion fire, I recently did an assessment of resorcinol. Interestingly, there was a debate this past year about whether it would be classified as particularly hazardous. See Resorcinol not identified as a substance of very high concern - All news - ECHA (europa.eu)

What led me to this information was that Sigma had two different SDSs for the same chemical. I have contacted Sigma about this discrepancy. In my opinion, since Nov. 2020 Sigma appears to be changing their SDSs to the most extreme classifications for some chemicals without clear sources.

Sigma SDSs section 2 GHS classifications:

Acute toxicity, Oral (Category 4), H302 Skin irritation (Category 2), H315 Serious eye damage (Category 1), H318 Short-term (acute) aquatic hazard (Category 1), H400

Versus

Acute toxicity, Oral (Category 4), H302 Skin irritation (Category 2), H315 Serious eye damage (Category 1), H318 Skin sensitisation (Category 1), H317 Specific target organ toxicity - single exposure, Oral (Category 1), Central nervous system, Blood, H370 Specific target organ toxicity - single exposure, Oral (Category 2), Respiratory system, H371 Short-term (acute) aquatic hazard (Category 1), H400 Long-term (chronic) aquatic hazard (Category 3), H412

Regards,

Tammy Rechtin

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Leah Rae McEwen
Sent: Tuesday, May 25, 2021 11:22 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.

Dear Colleagues,

I concur with the need for more clarity around sources of data reported in SDSs from manufacturers and chemical suppliers. Requiring references is the norm in published scientific literature, why not this standard of quality and traceability in SDSs as a key source of information?

Just a note about the Safety & Hazard information in PubChem - this is sourced from many different agencies and other entities. These sources are documented under each entry with a link back to the original source.

The corrosive GHS symbol included for Pentadecafluorotoctanoyl chloride is from ECHA, for example. Specifically the source is the ECHA C&L inventory database, which compiles classification and labelling notifications from a number of companies as reported to ECHA per the CLP criteria (EU regulation).

https://pubchem.ncbi.nlm.nih.gov/compound/Perfluorooctanoyl-chloride#section=GHS-Classification

https://echa.europa.eu/information-on-chemicals/cl-inventory-database/-/discli/details/62650

PubChem is a service from the National Library of Medicine that provides information from other authoritative sources as reported. The motivation is to provide a starting point and where to link to find further information. It is incumbent upon the user to determine what information and source is relevant for their needs. PubChem is not an official classification entity for GHS or any other status of chemical substances.

I hope this may help generally. As a volunteer curator with PubChem, I am happy to have ideas for additional data and information sources.

Best wishes,

Leah

Leah R. McEwen
Chemistry Librarian, Cornell University
293 Clark Hall, Ithaca, NY 14853
lrm1**At_Symbol_Here**cornell.edu
+1 607.793.6217

---

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Sent: Tuesday, May 25, 2021 11:54
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.

> >Could we have a webinar or discussion about the differences in SDS? I have faced those many times and depending on the manufacturer there are really big differences.
>
That would be a great topic to take up in a CHAS chat. We did begin this discussion in the March CHAS chat this year on Quality Data For Safer Experiments.q You can see the notes from this session at
http://dchas.org/2021/03/11/quality-data-for-safer-experiments/

However, a more focused discussion on assessing the fit of a SDS to answering a lab safety question would be a good topic for a group discussion. Do we have any volunteers to lead this discussion?

Thanks for this suggestion!

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**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 membership chair at membership**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 membership chair at membership**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 membership chair at membership**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 membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas