Soap Warehouse Blog

Well you can thank the new OSHA GHS labeling system for that.

When we were using the HMIS labels and a MSDS, for an ingredient to be considered a hazard, a hazardous ingredient had to make up more than 5% of the product. With the GHS labels and new SDS's that amount has been lowered down to 1% to be deemed harmful. The temperature level for what is considered flammable was also lowered.

Therefore many products with certain dye colors, now have to be listed as having carcinogens, may cause cancer. Many other small amount ingredients have to show that they are Corrosive because they will cause burning to the eyes if exposed due to splashing.

The same item you bought at the first of the year with a HMIS label of 1,0,1 may now have to have a 2,1,1 rating.

Nothing has changed but the percentage that reporting must start and the ranking of the hazard. For instance that small amount of ethyl alcohol in a product that before was not even listed on the MSDS and carried no flammable rating, all of a sudden is on the SDS and may make the product flammable enough to rate it a 1.

And do not think customers are not going to notice all the red border warning labels showing up on the side of the products you are using. You need to be informed and prepared to be able to defend what you are using. It is not fair that the bleach you buy that is for industrial use is going to have the Exploding Chest symbol on it but that same bottle if sold in the grocery store will not.

OSHA is only able to demand things in the name of protecting the working sector, not the home consumer. What a double standard our government is creating.

But don't panic at all of it yet. At least for now just because the hazards for products are increasing the DOT hazardous classifications have not changed and even though a product may have health hazard labels all over it, it will still ship DOT non hazardous like it always has, at least for now. Unfortunately if a product was already DOT hazardous it will still be.

Be prepared and keep updating your SDS binders, it is going to be a long next six months.

I thought I would pas this along during this Safety Week.

With all the new OSHA GHS label and SDS requirements coming down, contractors that make up their own chemical mixes out in the field may need to make sure they do not cross the line and become manufactures in OSHA's eyes.

The definition of a manufacture to OSHA is "Companies which blend or mix chemicals must comply with the standard by transmitting the relevant label/MSDS for the components of their mixture (which they, in turn, received in good faith from their suppliers) to their downstream customers."

So as long as the contractor is the definite end user and is not handing down, giving (other than their employees for doing their work) or selling their chemical mixture to others (creating downstream customers) than they can use said mixtures but they still must be able to provide their employees with the SDS of the original chemical materials used to make the mixture and label mixture containers to the best of their ability.

They do not have to pay for testing, chemical analysis or creation of new SDS for the mixture for their employees. But they need have some knowledge about what they are doing, for example what not to mix together and to assume that a hazardous labeled for example "8 Corrosive" chemical when mixed to make a new solution will continue to pass on that "8 Corrosive" characteristic and be treated and labeled as such for use by their employees.

So be sure you label all mixtures no mater where they came from and fight the urge to physically share your greatest new chemical find with your fellow contractors. Better to give them a list of the ingredients and tell them to go mix it themselves.