From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU]
On Behalf Of Mayo, Bret
Sent: Friday, May 28, 2021 9:36 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: EXTERNAL EMAIL: [DCHAS-L] FW: [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
I don't like the pictograms either. I was in favor of them when they first appeared, but no longer.. One recent example underscores how pictograms have contributed to the "dumbing down" of some lab workers at the university where I work:
We attach a Tyvek tag to our liquid waste containers so researchers can record what they put inside. One section of the tag is used to indicate the primary hazard class for the contents. We rely on that information to determine where the container should
be stored when removed from the lab and relocated to an accumulation site. In one lab I noted that check marks were next to both "Caustic" and "Acidic". I called one of the grad students over to point out that the primary hazard class for the container could
not be both Caustic and Acidic and if they were mixing the two waste streams in one container it might also be dangerous. He looked puzzled but nodded understanding and I left. A few minutes later he found me in the hall and told me I was mistaken and wanted
to show me why. He and a colleague (these are both 2nd year grad students doing polymer synthesis) had produced two chemical containers (formic acid and potassium hydroxide) and the senior grad student pointed at the "Corrosive" pictogram on each
and declared, "See? They ARE the same." I spent the next 10 minutes explaining the definitions and differences between the terms Corrosive, Caustic, and Acidic, and emphasized that they should actually read the warning information and not pay so much attention
to the cartoons.
Bret Mayo
Associate Director of Environmental Health and Safety
Dept. 3300, PO Box 6050 / Fargo, ND 58108-6050
Office Phone: 701-231-6299
Cell Phone: 701-238-2720
Fax: 701-231-6739
Good points Mike. I also really don't like the pictograms. Most are easily understood but some are not. I much preferred the warnings. The SDS is now challenging even for those with a high level of technical skill to interpret relative
to the actual risks presented.
Zack
S.Z. Mansdorf, PhD, CIH, CSP, QEP
Consultant in EHS and Sustainability
7184 Via Palomar
Boca Raton, FL 33433
561-212-7288
The GHS was a terrific step forward in three ways - comprehensibility, globalization (in that it provided a ready-made system for countries that could not develop their own), and trade. But it has a serious flaw
compared to the original OSHA Hazcom standard. (Full disclosure - I was a member of the coordinating committee that designed the SDS and labeling systems.) For some endpoints, the GHS takes a "weight of the evidence" approach, whereas the old OSHA standard
mandated that a single positive well-conducted study was enough to establish carcinogenicity, mutagenicity, etc. Weight of the evidence determinations can vary widely, and sometimes for reasons unrelated to the scientific evidence. We've seen wildly different
SDSs for the same chemical. Sometimes the same manufacturer will classify the same chemical differently in different jurisdictions. Clearly, this is not a science-based decision.
This is less a problem in the USA than in some other countries, because the easiest way for a manufacturer to lose a big product liability case is to withhold information from users. Thank God for our contingent-fee
tort system. But we've still seen plenty of discrepancies.
I=E2=80™ll leave to the lawyers whether OSHA could go back to the "one positive study" approach without running afoul of trade law. But even if they can't, they could make it harder for a classifier to ignore positive
studies. One way would be to require a transparent, publically available analysis, disclosing the evidence relied on and the evidence rejected, for any "weight of the evidence" determination. Some of us discussed that possibility with OSHA during the Obama
Administration, and some preliminary efforts were underway, but of course they ended in 2017.
Fortunately, OSHA's current Hazcom rulemaking provides a splendid opportunity to push this issue again. The initial comment period ended last week, but hearings are scheduled for September, so there will be plenty
of chances for written and oral testimony and post-hearing comments. I know OSHA would welcome participation by members of the DCHAS.
Mike Wright
412-370-0105 cell
"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change the world."
Jack Layton
> 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?
I think I can suggest the reason for this. The SDS did not begin existence as scientific literature, but as industrial safety information provided by the manufacturer for the _industrial_ user, and that in a much less formal era
of the 1960s. There have been significant modifications since then but dragging it into the realm of scientific literature is clearly a herculean task still in progress and unlikely to be completed in the near future. That doesn't mean you should not continue
to seek that level, but there is little point in being incensed about the SDS not being at that level now or soon.
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).
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.
> >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
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