If you think that a Material Safety Data Sheet (MSDS) provides adequate information to determine if a process chemical could be hazardous to your product, think again.
The MSDS is part of a requirement to communicate information on chemicals that can be hazardous to the worker. In 1983, the Federal Hazard Communication Standard (HCS) commonly referred to as the Right-To-Know Law1 set up three pathways for communication of hazards: container labeling, employee training programs, and written MSDS.
The MSDS need not disclose all chemicals or chemical information. For one thing, not every chemical in use has or needs to have an MSDS, only those that meet the OSHA criteria of “health hazard” or “physical hazard.” These are hazards to employees, not necessarily hazards to the environment or non-employee populations.
If a hazardous constituent of a mixture is present at a concentration of less than 1% (0.1% for carcinogens), that constituent need not be disclosed. Thus a complex mixture (for example, a cleaning agent or metalworking fluid) may contain 0.8% of chemical A, 0.75% chemical B, etc. and these small concentration constituents can be, and often are, omitted from the MSDS even though the sum of all these unreported chemicals may be a large fraction of the whole.