C. Material Safety Data Sheets

which contribute to known hazards, and common names of the mixture itself.

c. Mixtures untested as a whole: Chemical and common names of all ingredients which

are health hazards and which are in concentrations of 1% or more, or carcinogens in

concentrations of 0.1% or more. Carcinogens are defined to be those established as

such in the latest editions of (a) National Toxicology Program (NTP) Annual Report

on Carcinogens, (b) International Agency for Research on Cancer (IARC)

Monographs, or (c) 29 CER Part 1910, Subpart Z “Toxic and Hazardous Substances,”

OSHA.

If any of the ingredients which do not exceed the concentration limits in the previous

paragraph could be released from the mixture such that they could exceed an established OSHA

PEL, or an ACGIH threshold level value, or could represent an occupational health hazard, their

chemical and common names must be given as well. The same information is also required for

any ingredient in the mixture which poses a physical hazard (as opposed to a health hazard).

2. Physical and chemical characteristics of the hazardous chemicals.

3. Physical hazards of the hazardous chemical, specifically including the potential for fire,

explosion, and reactivity.

4. Known acute and chronic health effects and related health information. This information

is to include signs and symptoms of exposure and any medical conditions which are

generally recognized as being aggravated by exposure to the chemical.

5. Primary routes of entry into the body (exposure control).

6. Exposure limits data.

7. If the hazardous material is considered a carcinogen by OSHA, LARC, or the NTP (see

1.c above).

8. Precautions for safe handling, including protective measures during repair and maintenance of apparatus employed in using the equipment and procedures for cleanup of

spills and leaks.

9. Relevant engineering controls, work practices, or personal protective equipment.

10. Emergency and first aid procedures.

11. Ecological information (environmental impact) if known.

12. Transport restrictions or guidelines.

13. Date of MSDS preparation or latest revision.

14. Name, address, and telephone number of the entity responsible for preparing and

distributing the MSDS.

15. Any other useful information.

Although this list appears straightforward, the M SDSs provided by different companies

vary significantly in quality. Many are incomplete, perhaps not always due to lack of

information. There are generic sources of MSDSs which are prepared by firms independently of

the original manufacturers and are possibly more free of bias. On June 3, 1993, the American

National Standards Institute approved a voluntary consensus st andard for MSDSs developed

by the Chemical Manufacturers Association in an effort to provide more uniformity in the

documents. Several industries claimed that there were problems with the new form which were

not fully considered. As a result, at the time of this writing, no consensus standard has been

adopted. A suggested ANSI list is available at an Internet location included in the references.

Provision of a MSDS at the time of the initial purchase of a chemical is a responsibility of the

chemical vendor, and if the vendor fails to provide it, it is the responsibility of the purchaser to

take the necessary steps to require the vendor to do so. A typical MSDS can be up to several

pages long, and a comprehensive file of hundreds of these, which might be required in a typical

laboratory, or thousands if the file is maintained at a central location in an organization, will be

bulky and difficult to maintain.



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Both the distributor of a chemical and the purchaser have a major problem in complying with

the requirement that a MSDS be provided to the user, where purchasing authority is widely

distributed, as it often is on a university campus. Many institutions permit direct delivery to the

actual location ordering a given material, while in others there is a central receiving point. In the

former situation, a chemical vendor may supply an MSDS to the first purchaser of a chemical at

the institution, but subsequent purchasers may not receive one, because they did not receive

a copy of the first one sent to the initial purchaser. Where all the separate purchasers of a

chemical are part of the same institution and located within contiguous confines of a single site,

it is probable that the vendor technically can meet the legal requirement of furnishing an MSDS

to the institution as an entity by providing a single MSDS to the individual laboratory first

ordering a substance. In a large research institution, this would result in a very incomplete

distribution of MSDSs. Designation of a single department, such as the safety department, to

receive all MSDSs from the chemical vendors and to establish a master file of them, with

perhaps some partial or complete duplicate files at other locations, will partially alleviate the

problem. These files would need to be in places that are easily accessible to the users for a large

portion of the day in order to approximate compliance with the requirement of being readily

available to the employees. The laboratory standard does not contain the language “readily

accessible,” but only requires that the employees know where they are being held by their

employer. However, the organization should still make arrangements to facilitate access. Unless

the information as to which unit actually ordered the material accompanies the MSDS, it would

be impossible to distribute them further internally, unless an individual department requests a

specific MSDS which they wished to maintain in their local file. However, unless each

department received a notice of the receipt of any revised MSDS and took the initiative to

upgrade their own files, the local files would soon become obsolete. This could lead to possible

liability problems if an employee assumed that the local files were current.

Some chemical manufacturers or distributors have avoided the entire problem, as far as they

are concerned, by sending an entire set of MSDSs for all of their products to corporations or

institutions with whom they do a substantial business. It is then up to the university or

corporation to decide how to distribute them properly to comply with the regulatory requirement

that any needed MSDS be readily available to employees.

If all chemicals are delivered to a central receiving location, a fairly straightforward, but labor

intensive, solution to the problem exists. A master file of all MSDSs can be maintained at the

central receiving location, as well as a list for each chemical of all departments or other definable

administrative units which have previously ordered the material. If a department is not on the

latter list for a given chemical, then a copy of the MSDS can be made and sent along with the

material when it is delivered. A revised M SDS would be sent to every department listed as

having the specific chemical in their possession. It would require that a copy of every purchase

order and/or invoice were sent to the department maintaining the file in order to maintain the

departmental lists. Although this sounds relatively easy, the amount of record maintenance

required and the time spent in checking the files would be substantial. For a major research

institution, the amount and variety of materials ordered, coupled with the large number of

independent administrative units, would probably mandate at least a full time equivalent clerical

employee for the program.

Computer technology has provided solutions to all or part of the management problem for

distribution of MSDSs within complex organizations in which the variety of chemicals is

numbered in the hundreds or thousands, instead of a few.

Although hard copy compilations of MSDSs are available either in print or on microfiche,

the most flexible approach is to obtain access to an on-line source of MSDSs or subscribe to a

vendor that will send an updated CD-ROM disk on a quarterly basis (this meets the 3-month update requirement). There are several firms which provide one or the other of these services.

Some of the same firms also fulfill a requirement for the users of hazardous materials that they

have access to a 24-hour emergency services on a per-call basis, although some provide a



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limited amount of free time each month. Access to a server computer housing the CD-ROM data

base through modems or a network is a useful service, but the user must be sure that license

requirements are met. If license agreements are available, then access can in principle be made

available to every user of chemicals in a facility with access (rapidly becoming the norm) to a

computer or terminal 24 hours per day through a network or modem. Both of these means can

provide access to a very large MSDS data base that is current and reliable. Providers of generic

data bases do assume the liability of ensuring that their information is correct, and this factor

contributes in part to the relatively high cost of computer MSDS data bases. The other major

reason is the substantial amount of research needed to keep up with all of the current published

material available.

The references which follow are unlike the normal journal citations in that they are Internet

addresses. These simply represent sites which provide, free of charge, access to a very large

number of MSDS. To access almost any manufacturers MSDSs and commercial providers of

MSDSs, one can enter use any Internet browser, access a search engine, and Type “Material +

Safety + Data + Sheet, or MSDS” and one will receive many pages of Internet links to which to

go. The following two references are simply two of the most comprehensive.



REFERENCES

1. http://hazardcom/msds/

2. http ://www.msdssearch.com/



D. Purchase of Regulated Items

There are a number of classes of items for which purchases must be carefully monitored for

compliance with safety and security regulations. Several of these can be purchased only if a

license is held by the individual or by the corporation or institution. There are many restrictions,

in addition, on the transportation of hazardous materials. Usually, the purchaser will expect the

vendor to be responsible for meeting these shipping requirements. However, there will be

occasions when the institution or corporation will initiate a shipment. It is recommended that a

subscription to a hazardous materials transportation regulatory advisory service be taken out

by anyone who ships any hazardous material frequently, due to the relatively rapid changes in

shipping regulations. Such information is also rapidly becoming available from on-line or CDROM computer services. Updated data is often being provided by the regulatory agencies

themselves.

1. Radioisotopes

The purchase of radioactive materials, with certain exceptions, is generally restricted to

those persons who are licensed to own and use the materials under one of the sections of Title

10, Code of Federal Regulations, usually Part 30. In this context, the word “person” is used quite

broadly. In Part 30, which provides the rules for domestic licensing of byproduct material,

“person” is defined as: “Any individual, corporation, partnership, firm, association, trust, public

or private institution, group, Government agency other than the Commission or Department...,

any State, any foreign government or nation or any political subdivision of any such

government or nation, or other entity; and any legal successor, representative, agent or agency

of the foregoing.” Clearly, virtually any assemblage of persons can qualify to be licensed to

own and use radioactive byproduct materials, if they can fulfill the licensing conditions

provided by Part 30 and have an approved radiation management program meeting the

standards of Part 20. In approximately half of the states, the oversight function to ensure

compliance with the standard is done by the state rather than the Nuclear Regulatory



©2000 CRC Press LLC



Commission (NCR). These are “agreement states.”

There are a few more definitions which will be useful. The federal regulations in Part 30

usually apply only to “byproduct material.” This refers to “...radioactive materials, other than

special nuclear material, yielded in or made radioactive by exposure to the radiation incident to

the process of producing or utilizing special nuclear material.” The NRC definition of special

nuclear material is lengthy, but essentially it means plutonium, or uranium enriched in the

fissionable isotopes U-233 or U-235. There are naturally occurring radioactive materials which

are mostly unregulated and there are radioactive materials made radioactive by using

accelerators. These latter materials are regulated by the states independently, not by the NRC.

Exposure to some natural radioactive materials, such as radon, are federally regulated under

some circumstances.

There are a number of classes of radioactive materials which do not require a license. If the

amount is less than the exempt quantity for a given material, as listed in Paragraph 30.71,

Schedule B of the regulations, a license is not required. The amount meeting this criteria is given

in Table 4.1 for a few of the radioisotopes most commonly used in research. The units are in

microcuries where 1 microcurie is equal to 37,000 nuclear disintegrations per second, since this

is the way they appear in the regulations. A set of units different from these has been

recommended by the International Commission on Radiological Protection, and is the one

commonly used in professional journals. In the International System of Units (SI units), the unit

of activity is the Becquerel (Bq) and is equal to 1 disintegration per second. A microcurie,

therefore, equals 37,000 Bq.

There are a number of other classes described in paragraphs 30.15-20 of 10 CFR, in which the

persons purchasing certain items containing radioactive materials are exempt from having a

license, although the original manufacturer must have had a specific license to allow production

of the unit. Among these are se1f-luminous devices and gas and aerosol detectors.

The amounts in Table 4.1 are very small and are usually exceeded in most research

applications. For practical research using radioactive materials, it is necessary to obtain a

license; a discussion of this will be deferred to Chapter 5. However, assuming that a license has

been obtained and a radiation safety program has been established satisfying the NRC (or its

equivalent in an agreement state; henceforth, when the NRC is mentioned, it will be understood

to include this addendum), there are still formal steps to go through in purchasing and receiving

radioactive materials.

In a research facility, it is common practice to establish a license to cover all users of

radiation at the organization. This is called a broad license and provides limits on the total

amount of each isotope that can be in possession of the licensee at any specific time. These

limits are normally chosen by the inst itution and approved by the NRC. If there are several

separate users, as is usually the case, the sum of all their holdings for each isotope,

Table 4.1 Exempt Quantities of Some of the Most Often Used Radioisotopes

Isotope



Quantity (pCi )



Calcium 45



10



Carbonl4

Cesium 137



100

10



Cobalt 60



1



Isotope

Iodine 131

Iron59

Mercury 203

Molybdenum 99



Chromium 51



1000



Nickel 63



Hydrogen 3



1000



Phosphorus 32



Iodine 125



1



Sulfur 35



Quantity (pCi)

1

10

10

100

10

10

100



including unused material, material ln use, and material as waste, must not exceed these limits.

Since each individual user cannot keep track of the holdings of other independent users, it is

essential that all purchase orders, as well as all waste materials, be passed by or through a



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