A Scientist, an Actor, a Businessman, and Unknown Toxicity

Many good jokes have a common setup to them. That setup involves a unique group of individuals and some sort of humorous interaction that ends with a punchline. So here is my setup for this blog. What do a famous scientist, an award-winning actress/comedian and a well-known businessman have in common? Let’s look at a quote from each of them.

  • From Werner Heisenberg, the scientist, and his book Physics and Philosophy: The Revolution in Modern Science:
    • Whenever we proceed from the known into the unknown we may hope to understand, but we may have to learn at the same time a new meaning of the word ‘understanding’.
  • From Gilda Radner, the actress/comedian:
    • Life is about not knowing, having to change and making the best of it, without knowing what’s going to happen next.
  • From Warren Buffet, the businessman:
    • Risk comes from not knowing what you’re doing.

Now, I don’t have the best punchline but there is a common thread in each of these. It is about the unknown.

As authors of Safety Data Sheets (SDS) and labels, when researching ingredients there are times when there are no acute toxicity data in the literature on an ingredient. When this happens, alarm bells should ring. There is a very specific thing that has to happen when ingredients have unknown acute toxicity. When that ingredient is a part of an untested mixture at a relevant concentration, Continue Reading…

Right to Know
Has Right to Know Gone Too Far?

Right to know regulations are great for employees. They help educate the employees to understand all of the hazards they may be exposed to. OSHA’s philosophy behind their hazard communication standard is based around the “right to know” concept. One key to the system is the training of employees to not only know about a hazard, but to understand the hazard. Some states have implemented individual right to know requirements to provide information to workers above and beyond the federal level.

One state in particular has gone way beyond and branched the right to know into the consumer sector. Yes, I’m talking about California and their Prop 65 legislation. According to the California Office of Environmental Health Hazard Assessment (OEHHA) website (click here), Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballot initiative in November 1986. The proposition was intended to protect California citizens and the State’s drinking water sources from chemicals known to cause cancer, birth defects, or other reproductive harm, and to inform citizens about exposures to such chemicals.

The list of chemicals covered by Prop 65 can be found on OEHHA’s website (click here). Note that they specify coverage to citizens, not just workers. This means that Prop 65 applies everywhere in California, not just workplaces where employees are trained to understand what the information really means. Continue Reading…

OSHA HazCom 2012
OSHA HazCom 2012 – One Month after the Deadline: What’s Different?

Where’s the Beef?

A better question to ask than the one posed in the title is “Where’s the beef?” Many will remember this 1980’s catchphrase uttered by Clara Peller in an advertisement for the fast food chain Wendy’s. The purpose of this advertisement was to differentiate between the big name sandwiches provided by McDonald’s and Burger King and Wendy’s own Single. The difference was in the size of the bun used by the competitors and the large beef patty used at Wendy’s. (Click here for the Wendy’s Commercial)

For those in the hazard communication industry, the question applies because of the June 1st deadline. This deadline was for all safety data sheets (SDS) and labels to be updated under the new OSHA HazCom2012 format. It is now after July 1st and many downstream users are asking “Where are the updated SDS and labels” much like in the Wendy’s commercial. Granted some companies made the deadline and are supplying the new versions of the documents. Unfortunately, there are a great many that have not.

So, are things really different?

Many on the business side of manufacturers, importers and distributors, the answer will likely be, “not much”. The business is still manufacturing product, importing goods and distributing items. That process has not truly changed. From a Regulatory or Compliance point of view the answer to that is “yes”. If your company has not Continue Reading…

Safety Data Sheets (SDS)
SDS Research for OSHA HazCom 2012

The Next Revolutionary War?

For many, this transition period to OSHA HazCom 2012 from the Hazard Communication Standard of 1994 can best be summarized by Thomas Paine’s famous quote, “These are the times that try men’s souls.” While it was used in the pamphlet The American Crisis to deliver the ideas of the Revolution to the people of early America, there are many in the throes of classifying chemicals, substances and mixtures that feel this quote applies to daily life.

There is pressure on SDS authors, either internally or externally, to “get it right”. How can we be sure our classification is accurate? Did we cover all the hazards? Did we use the correct data?  Should we check other sources? These last two questions can be the most difficult to answer.

To be a “good” SDS writer, never stop at just one source of data. Since OSHA chose not to use the exact language out of GHS Revision 3 and only selected certain building blocks when developing HazCom2012, care should be taken when utilizing classifications from other world areas. One has to remember that many other world areas did the same thing. Using classifications derived under another country’s system could lead to some over-classification, or under, depending on which country’s system is used.

A prime example of this would be Toluene. A straightforward colorless, insoluble, liquid chemical used mostly as a solvent, Continue Reading…

OSHA Labeling
It’s What’s Inside that Counts — OSHA Labeling of Shipped Containers

Sometimes, regulations don’t give us all the answers we need. For example, many people are confused about the labelling requirements found in the Hazard Communication Standard (HCS) of Part 1910.1200 of the Occupational Safety and Health Act (OSHA). This section tells us that we must label all “shipped containers” that contain hazardous substances destined for workplace use. But what exactly is the “shipped container,” when you have inner containers inside an outer one?

The simplest form of “shipped container” is a single packaging. This is a packaging such as a drum or bag, with no inner containers. Such a packaging must be labeled according to the HCS, if the product is hazardous and is intended for a U.S. workplace. If the product is also regulated as a hazardous material for transport according to the Department of Transportation (DOT), then we must also display DOT labels and marks as required by 49 CFR.

However, it gets murkier when we look at combination packagings. These packagings consist of an outer packaging as well as one or more inner packagings. In a transportation sense, both the inner and outer packagings are “shipped.” But are they “shipped containers”?

The answer to this question isn’t found directly in the HCS. Instead, OSHA has issued interpretations that provide guidance here and here. (Note that one of these interpretations was issued long before the current rules, known as Hazcom Continue Reading…

HazCom 2012
HazCom Labeling – Are You Ready?

Deadlines Approaching

As of now we should all know or have at least heard that OSHA adopted the hazardous chemical labeling requirements in the latest revision of the Hazard Communication Standard. By aligning with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals or GHS, OSHA helps ensure uniformity in the labeling of chemicals. These updates will provide workers with better information on safe handling and usage of hazardous chemicals. Therefore, providing a systematic approach for avoidance and exposures to hazardous chemicals, reducing injuries and illness through worker awareness.

The upcoming June 1, 2015 effective date, manufacturers, importers and distributors can maintain compliance with the requirements of HazCom 1994 or the revised standard. However, manufacturers, importers, and distributors may start using the new labeling system in the revised Hazard Communication Standard (HCS) before the June 1, 2015 effective date. Hazardous chemicals shipped after June 1, 2015, are required to be labeled with the identified elements including pictograms, signal words, hazard statements and precautionary statements. Distributors have until December 1, 2015 to ship containers labeled by manufacturers or importers in compliance with the HazCom 1994, after which it is required to comply with the HazCom 2012.

Label Elements

According to the revised standard the required information regarding chemical hazards must be communicated on labels using visual cues for awareness to the users. Labels, defined in the HCS, are Continue Reading…

OSHA Labeling
Workplace Labels – An Essential Part of Workplace Safety

Nola Murphy’s Story

It was in a soft-drink bottle. It looked like lemonade. But 73-year-old Nola Murphy discovered, after pouring herself a glass, that it wasn’t. In fact, it was a toxic mould-remover that a cleaner had left sitting on a restaurant bar. The cleaner had poured the product from a larger container into the soft drink bottle for easier handling.

Mrs. Murphy was lucky – she survived the experience, although she required emergency hospital treatment. But her story, given in an article in the New Zealand Medical Journal, shows how putting hazardous chemicals in unlabeled containers can be a recipe for disaster. (More: The New Zealand Herald)

Many countries, including the United States and Canada, require hazardous chemicals sold to the workplace to be labeled by the supplier. Regulations such as the U.S. Occupational Safety and Health Act (OSHA), and Canada’s WHMIS (Workplace Hazardous Materials Information System), set out the basic requirements for such labels (called “supplier labels” under WHMIS, and “labels for shipped containers” by OSHA). But as Mrs. Murphy’s experience shows, many hazardous chemicals still end up in unlabeled containers. They may be poured (“decanted”) from larger containers for convenience. The original supplier label may have been damaged or removed. Or two or more chemicals in separate containers may be mixed together to make a new product. No matter how it happens, unlabeled chemicals create a Continue Reading…

Department of Transportation Logo
Transition Period for Two US Labels Coming to an End

On July 20, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published Final Rule HM-218F, bringing changes to the 49 CFR Hazardous Materials Regulations (HMR). Most of the amendments that were adopted in the final rule were intended to eliminate, revise, clarify or relax regulatory requirements. Two hazard class labels were revised in the final rule and were given a transition period for compliance until October 1, 2014.

Class 6 Label Changes

Class-6-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of CDC information on the class 6 infectious label

Prior to HM-218F, labels for Class 6 Infectious Substances were required by the HMR to include references to the Centers for Disease Control (CDC). The final rule removed the previously required statement “In U.S.A. Notify Director—CDC, Atlanta, GA 1–800–232–0124” from the label text. As of October 1, 2014, the statement must not appear on the Infectious Substances label.

Class 9 Label Changes

Class-9-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of horizontal line on the class 9 miscellaneous label

In 49 CFR, the Class 9 label was different from international regulations by including a thin, horizontal line running across the label at its midpoint. This led to some shipments being delayed or having to be relabeled by international carriers because there was no line required in the international standards such as the International Civil Aviation Organization (ICAO) Technical Instructions and the International Maritime Dangerous Good (IMDG) Code. HM-215F removed the requirement for the line on the Continue Reading…

What Is a CAS Number?

Here at ICC Compliance Center and depending on your application, we may ask you for a CAS number. When we create labels on demand for your exports, among other services, we will ask you to provide us with the chemical name and CAS number and then we are able to provide as few as 100 GHS compliant labels  and/or a compliant SDS.

Compliant GHS Chemical Label:

Compliant GHS chemical label

A CAS number or CAS Registry number is a unique identifier for every chemical substance dating back to 1957. The Chemical Abstracts Service (CAS) is the responsible entity that is responsible for assigning a unique number to every chemical described in scientific literature.

A CAS number itself has no meaning. Its primary use is to avoid confusion between chemicals with similar names, or individual chemicals that may have multiple names. It is also used to identify the chemical when a generic or trade name is used.

A CAS Registry Number is separated by hyphens into three parts, the first consisting of up to seven digits, the second consisting of two digits and the third consisting of a single digit.

In short, the CAS number can be particularly useful in database searches because it allows you to search a database and easily pull every record for that particular substance or chemical. For example, “Methanol” is known by multiple names such as methyl alcohol, methyl hydrate, hydroxymethane and Continue Reading…

A Tool to Combat a Necessary ‘Evil’: The New Fuel Economy and Environment Labels

Have you gone car shopping lately? Once you pull onto the car lot, there are many things that attempt to get your attention – shiny cars, big sales signs and air-pump-filled waving ‘things’. My focus is the cars. My focus is saving money. My focus is having as little impact on the environment as possible. Admittedly, a car is an expensive, necessary evil that once you see one, they all start blurring together.

A row of cars

Thanks to the Environmental Protection Agency (EPA) and Department of Transportation (DOT) I can make a meaningful distinction between these blurry pieces of metal. Starting with model year 2013 a newly redesigned Fuel

Economy and Environment Label will provide the public with new information on vehicles’ fuel economy, energy use, fuel costs, and environmental impacts.

For the first time, comparable fuel economy and environmental ratings will be available for all new vehicles, including advanced technology vehicles such as plug-in hybrids, electric cars, and E85 flexible fuel vehicles (FFVs).

Transformative Overhaul

The new labels, are the most transformative overhaul in the 35-year history of EPA’s labeling program, and will provide more comprehensive fuel efficiency information and five-year fuel costs or savings compared to the average vehicle, as well as environmental impact information.

There are three reasons EPA and the DOT is revising the label. First, the labels will provide consumers with more information in order to help save money on Continue Reading…