Rank: New forum user 
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Hello all, I have a question regarding MSDS. I am currently reviewing some of these for work using the information for a COSHH assessment. Going through the 16 sections I notice that some of the information is contradictory, I have added a link to one I am working on and hope that you would not mind downloading it so that what I am saying makes sense http://www.ilfordphoto.c...es/20141021932251888.pdfIts from Ilford photographic for something called Hypam Rapid Fixer. In general I can see that it is a possible irritant to eyes and skin and that it may also be an irritant if inhaled it is also non combustible. No pictograms are required but gloves and eye protection are required. In section 12 it is not regarded as harmful to the environment and in section 11 it has not been tested for health effects so there are no specific health warnings noted except it may cause temporary eye irritation yet further down in the same section under aspiration hazard it reads like its a real problem Also in section 16 there are 6 R phrases and 5 hazard statements which are telling me that it causes severe burns and it is flammable along with several other problem including it may cause infertility. The question I have is why the conflicting information and if you were using this for an assessment what would you do? Happy to answer any questions, thank you for you time. Ian
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Rank: Super forum user
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Why be surprised?
A study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’.
ECHA – REACH-EN-FORCE2
In any event safety data sheets need to be treated with extreme caution when considering risk assessment as required by COSHH. They are not intended for COSHH and only contain limited information. Your product may contain a whole raft of constituents that are harmful, particularly if in contact with the skin, that will never appear on the safety data sheet, simply because they have never been allocated a risk phrase, or now a hazard statement.
The latest guide on patch testing for allergens contains some 4,350 chemicals, of which less than 5% will have been classified as H317.
Also remember that when you use chemicals you frequently change them and may change the hazard that they represent. If you consult the sixth edition of the COSHH ACoP you will see that this now covers this. Just take a look at paragraphs 10 and 57.
In my work I frequently encounter risk assessments based on the safety data sheet information that are invalid.
Chris
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Rank: Super forum user
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Ther key Hazards identification for the classification is in Section 2 Section 3 has the Composition/information on ingredients. In your case, all the items in Section 3 are between 1 to 5% and as a whole, as per the suppliers classification, it is "Un-classified" --which means as per the thresholds used in the classification, does not lend itself to any risk phrase /hazard statement/symbol. 2.1. Classification of the substance or mixture Classification (EC 1272/2008) i.e. as per CLP Physical and Chemical Hazards ---Not classified. Human health--- Not classified. Environment-- Not classified. Classification (1999/45/EEC)--- Not classified. [ as per EU Dangerous Preperations Dirtectuive (DPD)] Pls refer to what each section of an SDS refers to:( We should no longer refer to MSDS) http://www.hse.gov.uk/reach/resources/reachsds.pdfhttp://www.hse.gov.uk/ch...g/safety-data-sheets.htmhttp://echa.europa.eu/do...s/10162/13643/sds_en.pdf
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Rank: Super forum user
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I remember around 2 years ago reading a SDS from a water treatment company and which stated there were no significant risks but their product should be used in a well ventilated area which it was. However, our engineers were reporting they could not breathe when using it.
I went to the company in question and they informed me they got their SDS from an external company. Something along the lines of they provide a product or chemical name and the external companies software generates a SDS. This is what I was informed.
I spoke to them about the issue and I later received a new SDS which pointed out the product was an Oxygen Scavenger and that a particular mask must be used when using the product.
Now considering I am not a chemist I was relying on the SDS and which was initially significantly incorrect. I think some suppliers do not fulfill their responsibilities and do not invest the proper resource into the information they provide.
I am always wary of what is written in an SDS these days.
Regards
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Rank: Super forum user 
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The link to the guidance documents is the real starting point for understanding the received document.
Section 2 is the suppliers (listed in Section 1) classification of Hazards by either a long winded set of calculations or more commonly via a software authoring package / external provider - this considers cumulative and additive effects of the various hazards associated with the individual substances (ingredients) in the mixture. NOTE: the section 1 supplier may only be a distributor / retailer and not the actual formulator or manufacturer of the product.
Section 3 lists those substances involved in the mixture that the provider has chosen to declare (there is no EU obligation for 100% formulation by either band or exact percentage) - here the Hazards statements (previously Risk phrases) are those associated with the actual substance in its as supplied form. As the majority of these tend to be abbreviated to code numbers a broader explanation can be required.
Section 16 sets out in detail as an explanatory appendix what the Hazard Statements & Risk Phrases mean - this list is for all codes noted in the SDS including those specific to the substances involved. The classification process means that all/some or none of theses statements / phrases in Section 16 are applicable to the mixture as listed (or not) in Section 2.
For example Acetic Acid is considered flammable (Section 3), as a diluted solution it is non-flammable in the mixture (Section 2) but as H226 has been listed there is an explanation of this code (Section 16).
The mixture itself may not have been tested but there is information for several of the substances involved - it is this information that populates Sections 8, 11 & 12.
So again Acetic Acid as supplied is H314 Skin Corrosive 1A - diluted its hazard reduces eventually being listed as an irritant.
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Rank: Super forum user
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The link to the guidance documents is the real starting point for understanding the received document.
Section 2 is the suppliers (listed in Section 1) classification of Hazards by either a long winded set of calculations or more commonly via a software authoring package / external provider - this considers cumulative and additive effects of the various hazards associated with the individual substances (ingredients) in the mixture. NOTE: the section 1 supplier may only be a distributor / retailer and not the actual formulator or manufacturer of the product.
Section 3 lists those substances involved in the mixture that the provider has chosen to declare (there is no EU obligation for 100% formulation by either band or exact percentage) - here the Hazards statements (previously Risk phrases) are those associated with the actual substance in its as supplied form. As the majority of these tend to be abbreviated to code numbers a broader explanation can be required.
Section 16 sets out in detail as an explanatory appendix what the Hazard Statements & Risk Phrases mean - this list is for all codes noted in the SDS including those specific to the substances involved. The classification process means that all/some or none of theses statements / phrases in Section 16 are applicable to the mixture as listed (or not) in Section 2.
For example Acetic Acid is considered flammable (Section 3), as a diluted solution it is non-flammable in the mixture (Section 2) but as H226 has been listed there is an explanation of this code (Section 16).
The mixture itself may not have been tested but there is information for several of the substances involved - it is this information that populates Sections 8, 11 & 12.
So again Acetic Acid as supplied is H314 Skin Corrosive 1A - diluted its hazard reduces eventually being listed as an irritant.
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Rank: New forum user
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Thank you all for your responses,it looks like I have a bit more reading to do on the subject. The information regarding REACH and SDS is interesting and may take a bit of time for me to digest.
A point noted from Roundtuit about the difference from section 3 and 2 and the lists of R phrases in section 16 may help with some of my issues in that the raw chemicals may carry a higher risk but when combined and diluted the hazard is reduced. Hope I have understood that?
It seems that SDS are not as foolproof as I thought.
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Rank: Super forum user
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The problem with safety data sheets is that in most situations they simply do not tell you what you need to know. Your risk assessment needs to be based on the hazard that arises during a task using one or more chemicals. This is not as simple or straightforward at might, at first, appear.
Take an aerospace company using epoxy pre-impregnated carbon fibre sheet. Company was being sued for allergic contact dermatitis from contact with this sheet, 60% of which was a chemical classified as a skin sensitiser. However, a test carried out by the Health and Safety Laboratory showed that the mat, as being used by the employee, did not release any of the sensitiser, i.e. this was not bioavailable and could not have caused the skin reaction. (Investigation revealed a different, non-occupational cause for the skin condition.) However, in another area of the site the mat was being softened with a solvent. This released the sensitiser and created a significant risk of allergic contact dermatitis. Same material, different usage and therefore a different hazard.
You mentioned dilution. This does not always reduce the hazard. For example, 2-butoxyethanol will penetrate the skin neat, but diluted in water (as happens in practice when it is used) increases the skin penetration rate.
It isn't as simple as many assume which is why many risk assessments are of doubtful validity!.
Chris
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