NOT SO-- The MSDS is a document that is written to meet the OSHA
requirements regarding contact with chemicals in an industrial setting.
I write MSDS on a regular basis, even when, by law, no MSDS is required.
OSHA requiers an MSDS be available for each and every HAZARDOUS
chemical.  It also requires that the MSDS be written to address specific
goals.  There are two big problems with MSDS .  First is that the
unknowledgeable try to over-apply them and second is that in many cases
they are being written to facilitate this over-application.

It simply is not reasonable to try to tell everyone in the world what is
in everything in the world.  The problem comes when we add in consumer
items, all of which are not even covered by the MSDS section of the OSHA
laws.   (OSHA covers only non-consumer chemicals used by employees).  If
the consumer protection people want to get busy and write a law that
makes someone write a document that does that, fine-  I don't need to
address that issue here.  But the MSDS is NOT intended to do this, and
as I said, to attempt to do so is a major over-application of an
INDUSTRIAL communications device.

Phil Anderson
Technical Director
Aqua Science, Inc.


-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
List Moderator
Sent: Friday, September 10, 2004 9:45 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Managing Chemicals with stench characteristics

Date: Fri, 10 Sep 2004 10:37:55 -0400
From: "Mary M. Cavanaugh" 
Subject: RE: [DCHAS-L] Managing Chemicals with stench characteristics

While I don't think that the lack of information on MSDSs is generally
intentional,  if you look at the body as a whole, MSDSs are not
accomplishing what OSHA intended. That is, they aren't telling people
enough of what they need to know.

There are good MSDSs, even very good ones, out there.  But there are as
many that give virtually no useful information (lots of canned generic
phrases), or the information is so technical as to be useless to the
material's actual users.  Sometimes even the information is overly
cauktions -- perhaps because of fears of liability, or perhaps because
the MSDS was written for the industrial setting where the product is
manufactured in huge vats, rather than for the 1/2-pint can the end-user
buys.

I spent almost 2 years entering MSDS information into the military's
MSDS database. I remember the fire section for solid potassium salt as
"flush with water".  I remember seeing the MSDS for a kind of rat poison
saying "keep away from children" in the precautions section and "no
ingredients recognized as toxic" in the ingredients section.  Symptoms
of overexposure routinely list "urticaria," "hyperlacrimation" and other
medical terms that most end users don't know.

A lot of the problem is, in my opinion, the way the MSDS regs are
written. There is no requirement to include chemicals that haven't been
evaluated for toxicity (which leaves tens of thousands of chemicals off
the ingredients list).  This probably was done to appease industry when
the reg was written, but it's time for this to change.

-mmc

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