Ralph, Chemical reactivity, even under the GHS is not properly addressed. I agree.
One of the things I want is just so simple. I just want the required listing of all 10 toxicity tests in Section 11 and when they have never been done to clearly indicate this with the words "no data available." This simple requirement along with a discussion on the Precautionary Principle and that in the absence of data, it is not wise to consider a chemical safe would alert consumers. Instead, they find one old LD50 and no other information and consider the chemical "safe" if not ingested.
The original impetus for REACH was the massive numbers of chemicals available (CHEM CAT says 32 million unique chemicals are now available) and the paucity of chronic data (a little over 1000 chemicals with IARC classifications). And my big beef is the 30,000 or so HPV chemicals they identified that have no chronic data. For gosh sakes, this is just nuts.
R & D = step1) synthesize a new chemical and step 2) find a market for it. People need to KNOW that is the case and when it is clearly understood by the average person, their collective common sense will kick in.
Monona
----Original Message-----
From: Ralph Stuart <ralph**At_Symbol_Here**RSTUARTCIH.ORG>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Jan 17, 2022 11:15 am
Subject: Re: [DCHAS-L] OPR&D article: When Safety Data Sheets are a Safety Hazard
> >I have to wonder why authors don't say more correctly that the E.U. gave us until 2015 to do it after which they would no longer accept our exports so the US made it mandatory in 2013 and required SDSs be available by the 2015 deadline.
It is interesting to note that the UK is facing this problem now that it has exited the EU and the UK government decided it wanted to go its own way on chemical safety information, in the name of loosening "restrictive regulations". See
https://www.natlawreview.com/article/uk-proposes-to-extend-uk-reach-registration-deadline-and-explore-alternative for the tip of that iceberg.
In my mind the more interesting aspect of the OPRD article is that it comes on the heels of our discussion of sources of chemical reactivity information. The article serves as a reminder that SDS are designed around each chemical in isolation and that chemical reactivities are quite irregularly reported on SDSs. I appreciate everyone who shared their "go to" sources for this kind of information. It's great to have this list to work from as the need for lab risk assessment of chemical interactions arises.
- Ralph
Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org
