From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Subject: Re: [DCHAS-L] GHS Busters
Date: Fri, 22 Nov 2013 13:40:52 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 8D0B5C98132F17E-21A0-58C3D**At_Symbol_Here**webmail-m269.sysops.aol.com
In-Reply-To <03cb01cee731$4761d250$d62576f0$**At_Symbol_Here**chemical-safety.com>


Neal. I never assumed CHAS would be involved in the oversight.  I just said some form of oversight should exist.  I'm fully aware that CHAS is not suited for such an undertaking.   And when some brave individual suggested doing it, I was also surprised because this is huge.    
 
When I originally wrote this, I was thinking of a group of lawyers ACTS is affiliated with: the NY Environmental Law and Justice Project. We have legal interns at our disposal and I might suggest something like this. 
 
Or Earthjustic: another roving band of attorneys.  In fact, Earthjustice has done some corporate adverse PR in the past.  About 7 years ago they published the actual composition of a flock of cleaning products and compared them to what the MSDSs listed which was, as expected, in most cases quite different.  I did a Washington  Senate Staff Briefing with Earthjustics when my last book came out in 2011 and I know they are my kind of meshugas. 
 
 
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062
actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 
-----Original Message-----
From: NEAL LANGERMAN <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Nov 22, 2013 7:23 am
Subject: Re: [DCHAS-L] GHS Busters

 
While I love listening to you and support many of your thoughts, I must step in here.  CHAS cannot ( and will not as long as I am an elected Officer) assume the liability of this suggestion.
 
I deal with the problem of chemicals listed differently in multiple jurisdictions on a daily basis, particularly when authoring a SDS.  I am not happy with the situation, but global States are independent and companies do their best to meet the requirements.
 
CHAS cannot set itself up as the judge.  If you (or anyone) wants to prepare a manuscript for JCHAS along these lines, we will gladly review it.  Similarly for a presentation at a National or Regional meeting.  However, if accepted or presented, the full liability falls on the author, not on CHAS.
 
Sorry to rain on the parade, but I do not want to try to defend the indefensible.
 
nl
 
------------------------------------------------------------------------------------
Standard confidentiality terms apply
 
NEAL LANGERMAN, Ph.D.
ADVANCED CHEMICAL SAFETY, Inc.
PO Box 152329
SAN DIEGO CA 92195
011(619) 990-4908 (phone, 24/7)
 
 
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Jaime Steedman-Lyde
Sent: Thursday, November 21, 2013 4:35 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] GHS Busters
 
That would make a really good paper/presentation!

Jaime Steedman-Lyde, CIH
Health Science Associates
www.healthscience.com
On 11/21/2013 2:39 PM, Monona Rossol wrote:
I hope you are right.  My point is that with no oversight, things either don't improve or improve so as you would barely notice.   My suggestion is that we look at methods of oversight.   Suppose the Chemwatch raw data were reworked by company to identify, not the countries, but the corporations that do good jobs and those that don't.  Might help.  But with now one looking or caring, it will just go on.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062

 
-----Original Message-----
From: BIALKE, THOMAS <tbialke**At_Symbol_Here**KENT.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Thu, Nov 21, 2013 3:46 pm
Subject: Re: [DCHAS-L] GHS Busters
I would bet that if you conducted that survey prior to GHS implantation, especially in the US you would get zero agreement. So 8% is an improvement. Far from perfect, but what did Chemwatch offer as a solution?
 
It is so easy to find fault and condemn an program without offering a solution.
 
Witness the Affordable Care Act.
 
Right now, GHS is the best we have.
 
 
Thomas Bialke
 
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: Thursday, November 21, 2013 1:25 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] GHS Busters
 
Thank you Ralph.   That supports what I'm seeing very well. I already wrote an article about that Canadian study of incorrect flash points.  
 
What it really boils down to is people are not reading the definitions and just making the same assumptions about their chemicals that they have always made.  
 
As long as there is no MSDS and no SDS oversight, why would manufacturers spend any more time or expertise writing their SDSs than they did their MSDSs.  Just get something out that looks right has been and still apparently is:  THE RULE.
 
And that is an established global system.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062

 
-----Original Message-----
From: Ralph B. Stuart <rstuart**At_Symbol_Here**CORNELL.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Thu, Nov 21, 2013 1:13 pm
Subject: [DCHAS-L] GHS Busters
I noticed an interesting article at
https://www.swiftpage6.com/speasapage.aspx?X=2Y0RSDXNI9G1KQ0R00YEWW
about the challenge of GHS:
 
What does GHS stand for?
 
The Excercise
Chemwatch have undertaken a systematic comparison of GHS classification 
published by official sources in:
 
Europe (ECHA)
Japan (NITE)
New Zealand (CCID)
Korea (NIER)
A total of 12,452 Substances were reviewed. 
 
Interestingly there was very little overlap between Substances reviewed by any 
two Jurisdictions - Korea and New Zealand reviewed 1494 Substances in common.
 
However, where Substances in common where assigned GHS Classifications, fewer 
than 8% were in agreement - New Zealand and the European Union agreed on only 75 
Substances of 939 Substances. 
 
In summary:
 
< 8%  Harmonisation between any 2 Jurisdictions
< 0.6% Harmonisation between any 3 Jurisdictions
===
I'm not quite sure of what to make of this data. I wonder if anyone on the list 
has done international comparisons that include the US?
 
- Ralph
 
Ralph Stuart CIH
Chemical Hygiene Officer
Department of Environmental Health and Safety
Cornell University
 
rstuart**At_Symbol_Here**cornell.edu
 

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