Bruce:

From the perspective of one who has authored >> 3000 MSDS/SDS documents, I have a bit of a problem with your position.  OSHA places risk assessment on the employer; but places hazard recognition on the chemical manufacturer/distributor/importer. When developing a SDS for a niche product, the author can do some risk assessment, but a problem I dealt with for years was convincing my employees to avoid including risk mitigation language in the SDS.  Too much risk information exposes the author to unacceptable liability.

That said, my position is that the author MUST provide specific information when possible.  PPE should define type and material (Neoprene/Nitrile/SilverShield™); define if the neat material is a RCRA waste if spilled; specific methods for spill clean-up including PPE scaled by spill quantity. 

But, avoid telling the employer how to protect workers.  The author cannot know the workplace.  Even in a niche market, words like “as appropriate” or “if necessary” must be used.  The risks of splash from a drum transfer by pump is different from a pour from a 4-liter container.

Yes, I get pissed when I review a SDS filled with “N/A” when my SDS will at least state “similar to water”.  Yes, I get pissed with “As required by applicable …”; but ultimately, the employer must take the hazard information from the SDS and do a risk assessment (we agree here).

As an SDS author, I like the feedback from knowledgeable end-users. I have revised many SDSs based on such feedback.

Finally, on this thread, I was around when OSHA issued 1200; and my company immediately started writing MSDSs.  The founders of 3E were based here in SD and I was doing training for them when they left General Dynamics to set up 3E.  They have succeeded beyond any dream.  Congratulations to them.  I am trying to retire – any failing – but the technology and industry demands are evolving.  I hope I am still here to see what replaces the GHS/SDS.

A real challenge to the next generation.

Neal

Michael,

I may or may not concur with your response.  Please let me re-state your perspective to make sure I understand your comment.  Please correct me if I am wrong. 

If you are not authoring enough SDSs to obtain/maintain proficiency, you should be relying upon vendors/contractors to perform the function. 

If routinely authoring SDSs or developing SDSs become a primary job responsibility then proficiency is required. 

The statement “authoring properly and with success” is the area I disagree with. 

Shouldn’t we be able to interpret SDSs received to determine adequacy? 

Today I received an SDS from a reputable manufacturer, upon review the SDS was inadequate and required me to re-evaluate my chemical exposure risk assessment, PPE required, etc. 

The 1984 OSHA HazCom Standard did not prescribe proficiency or professionally adequate SDS authoring.  Anyone else remember how MSDSs were initially received?  Initially, they included proper PPE protection, hazardous waste classifications, etc., but ended up being covered by generic statements with legal disclaimers, such as “Use adequate PPE”, “dispose of in accordance with federal, state or local regulations,” etc.? 

I believe the OSHA GHS standard will result in some manufacturer/employer being investigated, cited, etc., for exposing personnel to “recognized hazards”. 

My question is what sources were used, how were the risks evaluated, what are the scientific validity of the recommendations?  How was your assessment documented?  Can the assessment be justified in a court of law? 

We may be missing the task required to be accomplished.  Is the task to author a SDS or protect employees/downstream users?  My question is if you are an EHS Professional, are you going to rely upon a vendor/contractor to interpret that information for you while assuming the liability or allow them to perform the authoring while providing oversite/evaluation?  Will your employer/owner be satisfied with “I hired a reputable firm to author the SDS?” 

I would propose defining the learning track, defining success and stressing the ethical issue of performing those tasks within your areas of expertise as key components. 

Using contractors to author SDSs, regardless of qualifications, does not obfuscate our oversight responsibilities or liabilities.  I respect the feedback received from this list and would appreciate any other thoughts or opinions, since this is my opinion only. 

Thank you,

BruceV

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