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BernDaley  
#1 Posted : 12 February 2016 12:03:47(UTC)
Rank: Forum user
BernDaley

Any COSHH or chemical gurus out there?
I have a chemical with a datasheet saying one of its chemical components is classified as carcinogen under California Proposition 65. There is no other mention of any carcinogen properties anywhere else & I cannot get the percentage of that chemical into the substance as it states "the exact percentage (concentration) of composition has been withheld as a trade secret".
Not an expert so bit confused:
- what does the classification means?
- how do I find out if I need more control measures?
Thank you for your help...
Ron Hunter  
#2 Posted : 12 February 2016 12:30:42(UTC)
Rank: Super forum user
Ron Hunter

Roundtuit  
#3 Posted : 12 February 2016 12:36:01(UTC)
Rank: Super forum user
Roundtuit

Given the statement of "trade secret" and California Prop 65 it sounds as though you have been given an old US Safety Data Sheet - I would go back to the supplier and demand the correct EU format be supplied i.e. EC 1907/2006, EC 1272/2008 and either current EU 2015/830 or previous EU 453/2010.

Prop 65 does have some true carcinogens but in caution it also lists a lot of other substances based on very limited evidence.

If this SDS is the best your supplier is willing to offer check the revision date as HazCom 2012 meant that all US SDS must meet their interpretation of GHS from 31st December 2015 - any US SDS that pre-dates this without specific reference to 29 CFR 1910.1200 should be treated with great suspicion.

You should also note there is no US obligation to classify Environmental Hazards as these fall under the jurisdiction of the EPA rather than OSHA so it is possible pertinent information is missing.
Roundtuit  
#4 Posted : 12 February 2016 12:36:01(UTC)
Rank: Super forum user
Roundtuit

Given the statement of "trade secret" and California Prop 65 it sounds as though you have been given an old US Safety Data Sheet - I would go back to the supplier and demand the correct EU format be supplied i.e. EC 1907/2006, EC 1272/2008 and either current EU 2015/830 or previous EU 453/2010.

Prop 65 does have some true carcinogens but in caution it also lists a lot of other substances based on very limited evidence.

If this SDS is the best your supplier is willing to offer check the revision date as HazCom 2012 meant that all US SDS must meet their interpretation of GHS from 31st December 2015 - any US SDS that pre-dates this without specific reference to 29 CFR 1910.1200 should be treated with great suspicion.

You should also note there is no US obligation to classify Environmental Hazards as these fall under the jurisdiction of the EPA rather than OSHA so it is possible pertinent information is missing.
hilary  
#5 Posted : 12 February 2016 12:43:11(UTC)
Rank: Super forum user
hilary

In my experience there are a lot of things classified as dangerous in California which would be laughed at anywhere else. They have taken this to extremes.

However, if you are obtaining the product here you really need a UK or EU datasheet. The chemical composition of some products changes from country to country, particularly between different continents as they are very much dependent on what they can get away with in that country (as strange as it may seem). Therefore, any component that is potentially carcinogenic in California may not even be present in the EU product.

Hope this clarifies.
Kate  
#6 Posted : 12 February 2016 13:24:33(UTC)
Rank: Super forum user
Kate

Most things seem to be carcinogenic in California. Restaurant menus even have to identify the supposedly carcinogenic ingredients in the food. Do get the REACH data sheet instead and don't worry!
BernDaley  
#7 Posted : 12 February 2016 13:37:16(UTC)
Rank: Forum user
BernDaley

thank you all!
very useful answers...
just to clarify as I am in a bit of a battle (understatement here!) with our supplier: in UK the datasheet when requested should be EU or UK format not the US ones as they are supplying, is that a reasonable demand? according to them they don't see the problem! Oh I so love Fridays & this sort of battles!!!!
Roundtuit  
#8 Posted : 12 February 2016 15:08:27(UTC)
Rank: Super forum user
Roundtuit

The format is designated directly from the EU (UK CHiP regulations were withdrawn last year) so reference to regulations as per my previous post.

Uniquely for the UK - language of issue must be English and Section 8 Workplace Exposure Limits should reference EH40 (some suppliers give a table of all EU national limits)
Roundtuit  
#9 Posted : 12 February 2016 15:08:27(UTC)
Rank: Super forum user
Roundtuit

The format is designated directly from the EU (UK CHiP regulations were withdrawn last year) so reference to regulations as per my previous post.

Uniquely for the UK - language of issue must be English and Section 8 Workplace Exposure Limits should reference EH40 (some suppliers give a table of all EU national limits)
Kate  
#10 Posted : 12 February 2016 15:57:12(UTC)
Rank: Super forum user
Kate

Show them this: http://www.hse.gov.uk/reach/resources/reachsds.pdf
including the link within it to how a sds must be written.
Roundtuit  
#11 Posted : 12 February 2016 16:04:59(UTC)
Rank: Super forum user
Roundtuit

http://echa.europa.eu/do...nutshell_guidance_en.pdf

Would always recommend going straight to the horses mouth - the HSE publication being from November 2012 links to EU 453/2010 - this was replaced effective 1st June 2015 by EU 2015/830
Roundtuit  
#12 Posted : 12 February 2016 16:04:59(UTC)
Rank: Super forum user
Roundtuit

http://echa.europa.eu/do...nutshell_guidance_en.pdf

Would always recommend going straight to the horses mouth - the HSE publication being from November 2012 links to EU 453/2010 - this was replaced effective 1st June 2015 by EU 2015/830
Kate  
#13 Posted : 12 February 2016 16:17:12(UTC)
Rank: Super forum user
Kate

Good point!
stillp  
#14 Posted : 13 February 2016 21:56:46(UTC)
Rank: Forum user
stillp

I once stayed at a hotel in Silicon Valley, which had a large notice at each entrance stating that some years previously the hotel had allowed smoking in certain areas, and hence the hotel contained known carcinogens! The pool was surrounded by oil flares after dark...
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