An SDS preparer cannot underestimate or misrepresent the toxicity of the product. Therefore, if there are components that can cause irritation or other issues, they must be called out on the SDS. If the in vitro or other test data on the actual product show that not to be the case, then the preparer can put the results of the actual product test data on the sheet. This can help manufacturers if they think their product is less toxic than the chemistry appears (fewer warnings/less hazardous = good marketing). But the data must be available to support such claims.
Who Really Needs SDSs?
The powers that be determined that the individual consumer should have access to this information only on a “need to know” basis. Therefore, SDSs would not normally be found at the store on the shelves where food products are sold. SDSs are meant for:
- Employees who may be occupationally exposed to a hazard.
- Employers who need to know the proper methods for storage, safe use, etc.
- Emergency responders such as firefighters, hazardous material crews, emergency medical technicians, and emergency room personnel.
At first blush, the fact that consumers do not have access to this information seems counterintuitive; however, the real purpose of the SDS is to protect occupationally exposed individuals and not the occasional home consumer. For instance, most paints contain some rather harsh and toxic materials. If they didn’t, they wouldn’t work well. If painting were your profession and you were exposed to paint fumes for 40 hours a week, week after week, that SDS data might be considerably more important than it would be for someone who painted a room once a year. It all goes back to the age-old toxicology statement: “The dose makes the poison.”
Some companies put a considerable amount of information on their SDSs while others, not so much. As a rule of thumb, the data should be as complete as possible with the information at hand, with toxicological statements evaluated by a certified toxicologist. One should never speculate or overstate the effect of the product–as in all things scientific, be truthful and accurate.
Dr. Kapp, an independent consultant for EAS Consulting Group, has over 30 years of experience as a toxicologist involved with the management, development, and safety of new and existing products. Reach him at firstname.lastname@example.org.