A Tale of Two Material Safety Data Sheets (MSDS)
Not all MSDSes are created equal. Because what they are required to report is minimal, manufacturers take very different approaches to how much they disclose.
One of the first tools we use in product evaluations are Material Safety Data Sheets (MSDSes, or MSD Sheets). These data sheets, required by the U.S. Occupational Safety and Health Administration (OSHA) for all products, are designed to address occupational safety and provide a bare-bones assessment of the chemical hazards in a product. The problem is that what manufacturers are required to report is minimal, so disclosure levels are all over the map.
If you're looking for useful information to distinguish the health and safety of different products, the lack of data can be so frustrating as to be almost comical.
It was one of these comically useless MSDSes that prompted this post. GreenSpec products editor Brent Ehrlich emailed me with an MSDS attached, saying, "I was curious about [Name withheld]'s claims, so I decided to check out the MSDS. It's a beautiful piece of non-information. Poetic in its near complete absence of substance."
This got us on a roll with the good, bad, and ugly of MSDSes.
The Good: Full Disclosure
This MSDS for Gorilla Wood Glue (PDF) is short, to the point, and includes the full list of ingredients in the product and how much of each is in there.
This is all too rare--and that's part of the impetus behind one branch of the transparency movement we've talked so much about lately--including things like International Living Future Institute's "Declare" label and the Health Product Declaration.
The Bad: No Disclosure
Well, the aforementioned MSDS (pdf) really takes the prize. There is no information in it whatsoever, other than that the legal requirements for an MSDS don't give one much to go on. All we know here is that there are no reportable hazards at reportable levels, but whether or not there is anything that is an emerging concern, or lower levels of a hazard, cannot be determined.
A better contrast to the Gorilla Wood Glue MSDS, though, would be something in the same category, like the MSDS for Titebond's Original Wood Glue (PDF). Titebond provides no ingredient information: they don't have to, because there are again no reportable hazards at reportable levels. There is some indication from section 15 on the MSDS that there are hazards in the product--including at least one Proposition 65 chemical (a chemical that prompts a mandatory health warning in California), but these ingredients apparently haven't reached an amount requiring Titebond to tell us what they are.
The Ugly: Interpreting what you get
Here's the interpretation game we play. Lets first pretend that these products are otherwise equal, and that we're just trying to determine which is safer. Which do we choose?
Step 1: Who is hiding less?
We have one MSDS that doesn't disclose any ingredients, but has some warning indications that imply hazards are present, if below reportable levels. We have another MSDS that spells out all ingredients, with a list that includes known carcinogens and other hazards, but these are all far below reportable levels.
The MSDS rules only require a carcinogen to be disclosed if it makes up 0.1% (1,000 ppm) or more of the product by weight, and another health hazard to be disclosed if it makes up 1% (10,000 ppm). In contrast, the most rigorous system in use in the USA, the EPA's Design for Environment program, requires reporting of all intentionally added ingredients plus known residuals (trace amounts of chemicals impurities) down to 0.01%, or 100 ppm.
Here's the ugly part: In the MSDS with better disclosure, all of the listed hazards are below 100 ppm. The non-disclosing MSDS could have up to 999 ppm formaldehyde, for example, but the company just didn't not bother to tell us. If this were all I had to go on, I'd use the product with better disclosure because it's hiding less.
Step 2: Add your own chemical screening
Lets take a second look, using the Pharos Chemical and Material Library (member link), an easy way for non-chemists and non-toxicologists (i.e. most of us) to assess which chemicals are known hazards. That's where we find the hazards listed on the MSDS with better disclosure. A bunch of the main ingredients are listed in Pharos with no hazard info; that means they aren't on any of the exhaustive set of hazard lists that Pharos keeps track of.
Does that mean they're safe?
Not necessarily--it could mean they're simply less-known, less-tested chemicals, but it's still a good first step. Some of the other ingredients have an NJTS number, and these aren't listed in Pharos either. NJTS stands for "New Jersey Trade Secret" and is one of a variety of terms and lists used when an ingredient isn't disclosed because it's a trade secret. OSHA has a bunch of rules about when that is or isn't allowed, along with requirements on how the hazards of trade secrets should be disclosed.
Step 3: Demand better information
One possible next step would be to harass Titebond for more detailed information (something GreenSpec does on a regular basis--and which gets increasingly effective the more times they get asked, and the bigger the customers and projects demanding that info).
You could also harass Gorilla Glue for more proof of the hazardous or nonhazardous properties of trade secret ingredients. It's worth a try, and the more we all try, the more luck we'll eventually have (or manufacturers will just get tired of it and fill out a comprehensive Health Product Declaration).
So which product do you choose?
Let's say you didn't have any luck getting more info, so you're back to basing your decision on these two MSDSes (or trying to find an alternate manufacturer who will give you more info). Again, the one without disclosure could contain the same hazards at much higher amounts, so, somewhat counterintuitively, I'd go with the one that tells me what to watch out for.
It is of course rare that two products are exactly equal other than the MSDS. There may be cost or performance differences you are familiar with or myriad other concerns.
For reasons that don't have much to do with the MSDS, we haven't accepted either of these products into GreenSpec. Before even looking for what is in a product, the GreenSpec team typically checks for what is emitted from the product. With adhesives, whether flooring adhesives or general construction adhesives, GreenSpec looks first for products that both have low VOC content and are certified to California Section 01350 or other more stringent emission protocols.
Then we start looking for products that take the next step with greater transparency on ingredients and minimization of hazards. I could go on ad nauseum about the challenges with emissions testing, particularly for wet-applied products, and how we're making the best of the info we have, and where a better understanding of performance might change our assessment method further--but that's a topic for another post.
The main point of all this back-and-forth is to make it clear that at the end of the day, what you see on an MSDS is not necessarily what you get. It's worth understanding the ramifications of what you don't see, particularly when comparing products with more and less disclosure.
Posted by Jennifer Atlee on February 29, 2012
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