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Posted By mark linton
Two MSDS's for the same substance, one MSDS states that the substance is non-hazardous and the other says that it could be harmful to an unborn child.
Which do I believe? What is the easiest way of resolving this?
Thanks in advance
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Posted By Sean Fraser
The one with the risk factor noted - better to be on the safe side! :-)
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Posted By Neil R
Who are the two MSDS from?
If one is frm the manufacturer and one is from the supplier, take the manufacturer MSDS as the truth.
If they are are both the same, then contact the manufacturer and ask for clarification.
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Posted By Haggis JM
I have a similar problem with differences between UK and Norwegian MSDS - always work to the more stringent version.
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Posted By Michael L Baker1
I agree with previous post, just out of curiosity what is the substance?
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Posted By Paul Leadbetter
Mark
Have the two examples been written at different times? The difference may reflect an increase in knowledge about the hazards.
Paul
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Posted By Ron Hunter
MSDS and CHIP compliance is a general shambles.
I've seen some real shockers recently.
In turn then, compliance with COSHH tends to be haphazard at best.
If only the HSE would take a few prosecutions!
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Posted By Smurfer
Mark
I've come across this where there is a single datasheet for a range of different coloured paints. Generally all colours have the same formulation, but certain colours may also contain e.g. lead chromate. Thus there can be two datasheets...
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Posted By Kenneth Patrick
Mark,
What is the substance, name or CAS No.?
Ken
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Posted By Tanya Boyce
we use the worst case first then do further research into the product. Different phases (powder, liquid etc) can also cause different outcomes on MSDS
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Posted By Karim Al-Maslout
Check out this website http://hazard.com/msds/
It’s a great source of MSDS on-line.
Karim
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Posted By Chris Packham
Check the Approved Supply List. In the U.K. this is the definitive list and will tell you what risk phrases apply to the particular substance.
Of course, this does not tell you the hazards that could arise from the preparation, only the hazards of the individual constituents.
You can have something that contains potent sensitisers, but is a product that is innocuous. Stainless steel is a case in point, the technical name being chrome-nickel-steel, chrome and nickel being two of the more common sensitisers. It is then all about bioavailability. Neither substance is normally bioavailable in stainless steel, so the product does not initiate allergic contact dermatitis.
It is one of the reasons why MSDS are not really the correct source of data for the risk assessment. They simply are not intended to provide you the information you need.
Chris
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Posted By mark linton
The substance is diethyl phthalate. I have a collection of data sheets for this substance, two from suppliers and two pulled from the internet:
- One supplier data sheet makes no reference to any hazards.
- One supplier data sheet makes reference to evidence of reproductive effects but no R phase.
- One of the internet data sheets states that 'chronic exposure may increase the risk of reproductive defects'.
- One of the internet data sheets makes reference to 'possible risk of harm to unborn child' and has a R phase.
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Posted By Paul Leadbetter
Mark
I remember from some years ago that phthalate plasticisers were removed from children's toys because of the adverse health effects but I can't remember the cause for concern.
Paul
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Posted By Chris Packham
Perhaps one of the problems is that diethyl phthalate does not appear as such in the Approved Supply List. However, it does appear as a synonym under 1,2-benzenedicarboxylic acid. The Approved Supply List then states:
Rep cat 2, R61 Rep cat 3, R62
Just goes to show how confusion can arise and how careful one must be. I recently reviewed 30 safety data sheets when doing an audit for a new client. Only one was correct in all respects. Some of the others, if taken literally, could have resulted in situations where the risk of damage to health could have been significant.
Chris
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Posted By Jay Joshi
There is no doubt that there is a systemic problem with not only the authoring of MSDS's, but also with the interpretation of the information by users!
The classification & labelling of preparations is a complex matter and is dependent upon certain thresholds of concentration of a constituent in a preparation and the testing criteria used.
The toxicological information is provided in Section 11, but the risk phrases are dependent upon the technical requirements of classification.
There is useful information on the Chemical Hazards Communication Society website, especially its reference to the "Safety Data Sheet User Guide" which is a priced publication. Only if this was freely available and more widely publicised!
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Posted By Paul Leadbetter
Chris
Are you sure of that alternative name? The CAS number of your substance is 068515-42-4 but that for DEP is 84-66-2.
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Posted By Chris Packham
Paul
Take a look at the following URL:
http://environmentalchem...Diethyl%A0phthalate.html
I frequently use Lewis's Hazardous Chemicals Desk Reference which I obtained when working with the AIHA in the USA. OK, being American, just about everything is toxic, but I find it does tend to point me in the right direction.
Chris
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Posted By KayS
Hello,
Has anyone tried the HSE's COSHH Essentials Website? I have, but I'm stuck half-way through because the MSDSs don't show boiling point or vapour pressure - I need one or the other. I asked our supplier and they decided to contact the HSE about it because they don't think they need to provide those details!
Having read a few threads like this previously, and not knowing much about biology or chemistry, I was too scared to attempt a COSSHH assessment without help, but I have struggled to find practical advice for non-chemists.... I thought the COSHH website was the answer to my prayers but it seems not! is hiring a consultant chemist type person the only way to get a proper COSHH assessment done? Even then, how would I know if they did it right?!?
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Posted By Ron Hunter
HSE Coshh essentials tool tends to "struggle" with substances other than VOCs.
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Posted By DPK
Mark
I had an issue of conflicting information on a MSDS recently, i rang the company who supplied the MSDS and questioned them which they replied, oh yeah we know about that, you must have the old MSDS.
Oh don't worry then if it is just a typo after all the substance is only highly flammable???????
Numpties!
DPK
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Posted By Chris Packham
KayS
I gave a presentation on exactly this topic last week to part of the W. Midlands IOSH branch. If you would like a copy of the handout let me have your e-mail address and I will send it to you. I think it might help.
Chris
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Posted By Chris Packham
Upon reflection (over lunch):
Why are we so concerned about risk phrases on MSDS? After all MSDS are for CHIP not COSHH.
Risk phrases only apply to those substances that are in the Approved Supply List. Now if you consult your copy of the ACoP for COSHH and read paragraph 13 you will see that the ACoP is quite definite. The Approved Supply List is not the definitive list for COSHH as there are many substances not in the ASL (and thus also almost certainly not on your MSDS) that can be harmful to health.
Now consult regulation 2 on what constitues a dangerous substance, and particularly definition (e).
The conclusion has to be that if you rely upon the MSDS for your risk assessment you could easily miss significant hazards and end up with an invalid risk assessment.
Actually, we need to look beyond the MSDS. Go back to 1974, i.e. to the Health and Safety at Work etc. Act 1974, and consult section 6-1. This defines the information that the supplier is legally bound to provide. This is quite different to that he has to provide in the MSDS as it has to take account of how his product will be used. This is the information you need for your risk assessment, but how you extract this from the supplier is another story!
Chris
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Posted By mark linton
In my view you do need both the properties of the substance and how a substance is used to write a COSHH assessment - you would be hard pressed to do a thorough risk assessment missing either piece of information.
How you as a person or an organisation use a substance is fairly straight forward to identify but without MSDSs how would you go about identifying the properties of a substance. Very few people (in relative terms) would be able to extrapolate the properties of a substance from its chemical name, appearance or odour - a substantial testing regime for every chemical would be required.
It is the reason so many people rely on MSDSs and why people are always so taken a back when their confidence in MSDSs is shaken because it draws into question their COSHH assessments they have taken time to prepare. MSDSs are an imperfect medium but what is the alternative?
My original post is all about how we deal with these sort of issues / errors when we find.
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Posted By Chris Packham
Mark
I deal with it for my clients by referring back to the supplier requesting the information he is required to provide under section 6-1 of the Health and Safety at Work etc. Act.
Sometimes takes some persuasion, but usually I can get the right information.
I had a company recently who were about to implement expensive control measures due to the presence of a substance labelled R43 on the safety data sheet. My supposition that this would not be bioavailable, and therefore not a hazard, was proven correct by testing for its release. Cost of test was miniscule compared with what the company thought they would have to spend.
Chris
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Posted By Paul Leadbetter
Chris
I have looked at the link; thanks. You had left off 'diethyl ester' from the name you quoted; it makes sense to me now..
Paul
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Posted By Paul Leadbetter
Kay
An occupational hygienist, preferably with a chemistry background, should be able to provide a suitable and sufficient COSHH assessment.
You can find one here if you need one: http://www.bohs.org/reso...ame/1310/Web_edition.pdf
Paul
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Posted By TonyB
Hi Mark (and everybody else)
At the moment you should use the Approved Supply list, it should include all the R phases.
Another source is the EBC Classlab system.
http://ecb.jrc.ec.europa...belling/search-classlab/
This is the EU database from which the ASL is drawn. After the introduction of CHiP4 in April the ASL will no longer exist and the ECB database will be the definitive list, until the new REACH database is populated and up and running.
In is worth noting that all the symbols are changing over the next 5 years (starting for April) to the GHS symbols!! During the transitional period we're going to have two systems running side by side (deep joy!).
All the best,
TonyB
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Posted By Peter F
This appears to happen quite often, as on a lot of items there is a sign as irritant and when you read through it is registered as non-hazardous.
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Posted By Chris Packham
Keep in mind that the Approved Supply List is not comprehensive. For example there are several substances that dermatologists have included in their patch test series as being common skin sensitisers that have not been categorised as R43 and thus will not appear as such on any safety data sheet.
Relying upon risk phrases is in any case not recommended - see paragraph 13 of ACoP for COSHH. For a risk assessment you need to look beyond the safety data sheet.
Chris
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Posted By JimE
Hmph!
As the one-man band H&S department here I do the COSHH r/a. I too am having a lot of difficulty with insufficient/conflicting info and I am struggling with unhelpful companies and no management back-up to get the info I request.
I have no chemical background and rely on self teaching and this brill forum :).
I feel I must question my own competence to do an adequate COSHH r/a.
Should I hand the ball back to management to find somebody competent or carry on with sword hovering over my head and risk an employee being affected by a chemical we use because I didn't know it was unsafe?
MY apologies Mark I have hijacked your thread slightly.
JimE
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Posted By mark linton
No problem at all Jim - I am just as interested in the answers to your question as my own.
What would define someone to be competent to carry out COSHH assessments? Within my organisation I have scientists (with backgrounds in chemistry - more degrees and doctorates than a university I have been reliably informed) who religously follow the information on MSDSs, whether that be right, wrong or just mildly bonkers. I did some COSHH awareness training with some a while ago and was surprised that very few understood the CHIP warning labels. What hope for the lay man?
I am slightly better off than Jim as I have some background in chemistry (an A level) but I am can assure you I must have missed the lesson that dealt with COSHH - and I suspect the same is true of those guys I mentioned above.
My only view is that you do the best you can with the information available, if it isn't available (or you doubt it's accurancy) consult with an expert.
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Posted By Chris Packham
As I stated earlier, I have a handout for a presentation I gave to a local IOSH branch recently on just this topic. If anyone is interested drop me an e-mail and I will e-mail a copy.
Chris
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Posted By JohnV
Chris,
I'd be grateful if you could e-mail a copy of your handout please.
Many thanks & regards,
John
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Posted By Mike Wilcock
Hi Chris
i too would like a copy of your presentation. i only joined the forum today so total virgin as to how to procede. i will keep an eye peeled on my in box and this forum for further help
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Posted By Tanya Boyce
Hi Chris,
Could you send me a copy as well. Thanks.
I do COSHH for our company and as a fully trained scientist shouldnt struggle but sometimes finding the info is less than easy.
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Posted By KayS
Thanks for all the useful comments & ideas etc.
Further to my original post, our supplier came back to me saying that the [reference removed] had told him it was OK to use the Flash point in place of the Boiling point. He noted names, tel numbers & time/date of his calls to them. Knowing what could happen should there ever be any litigation, I thought I'd just email HSE confirming the instruction, so there was something in writing to prove their instructions. Surprise surprise, I got an email back saying the two figures are not interchangeable, but they didn't confirm or deny having given the dodgy advice. An internal cock-up at the HSE perhaps. They suggested that instead, I should look at the ingredients and google them to find the lowest boiling point, which would then be the one I should use on COSHH Essentials.
They cc'd our supplier in their response, so now I'm back to square 1 and awaiting news from the supplier, because he disagrees that the compound boiling point would be the same as that of one of its component parts.
What a palaver! Seems everybody (well, safety people and Management at least) has to be an absolute expert in everything, or have unlimited funds to spend on Safety provisions!
The law can get you no matter what you do or don't do ... depressing sometimes, isn't it :-(
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