The shock on their faces was palpable. A HazMat/DG instructor who didn’t know the answer to a compliance question? How could that be? Who would’ve brought in such a person to deliver training? And didn’t he seem to know his stuff otherwise? Can we trust anything else he’s said? Whoever admits they don’t know?
I didn’t let it last long. I followed up with “but I know how to find out”. And then we used the regulations to find the answer. And then we talked about how they could use a similar process when questions arise in the future. And they were relieved. They still weren’t sure whether I truly knew the answer or not, but they understood that I was creating a teachable moment either way.
I’ve done this over and over, for different courses and of course, different audiences. Most react the same way. Heck, sometimes people will ask me during a break whether I knew the answer or not. Usually I did know,and had just picked a topic that had the answer in the regulations where it was expected to be. Actually, most of my CDGP preparation course for the open book CDGP examination is based on my asking a lot of questions and answering every single one of them with “I don’t know”. Finding the answers quickly can be a learned and practiced skill, especially when the answer isn’t where it would normally be expected to be. But, just between you and me and the lamppost, sometimes I really don’t know. Shhh.
I wasn’t the only one though, at least once upon a time. Back in the old days when SDSs were MSDSs it was legal to say “I dunno” on them. Well, different words and acronyms were used, but they all seemed to mean the same thing. NA, unknown, not fully studied, not listed in the literature, —, not available, not found, use all reasonable precautions, and of course, . (That was a blank, by the way). At one of my employers we used to keep a champion of sorts, the best example of what we called The MSDS of Ignorance. It was indeed amazing to see an MSDS that said the form and color were both unknown. Um, how about you just look at what you’re selling and shipping, and then write down what you saw?
Who would create these MSDSs? To be fair, most weren’t candidates to be the champion MSDS of Ignorance, but they were more like Swiss cheese, with holes of varying sizes scattered about. Maybe they were written by a process safety person who didn’t know much about product safety. Or maybe they were copied from a competitor’s MSDS and just re-titled. I’ve heard of Distribution Managers being assigned the task. But probably most common, at least at mid-sized to small companies, was to assign the MSDS writing responsibilities to a QA / QC chemist, who at least knew most of the properties of the product, if a bit weak on figuring out which type of gloves to recommend.
Then, thankfully, things changed. GHS finally happened. Countries adopted lots of parts of GHS. Rules and regulations about not knowing were tightened up. The M was dropped, leaving us with SDSs. The holes were being filled, and if information or data was missing, that information had to be found or that data developed. Certainly, as a transport classifier for re-distribution of products, it was a lot easier to have information available, and I’m sure that in workplaces employees could better know what they needed protection from, and how to protect themselves.
But once that pendulum started swinging away from ignorance and toward information, it kept on going. More and more information was required. Explanations and warnings were expanded. Data underlying conclusions was provided, as if the reader of the SDS would use that data to verify or debunk the conclusion. I have a friend that for years has been bugging me to write a Porch Swing column about how a chemist can no longer write an mSDS. Certainly, it seems like a team is required to write a compliant SDS these days. Someone with a degree in information technology or library science to comb all the literature and databases for relevant information. A toxicologist to evaluate all the acute and chronic hazards in a variety of human systems and organs. An aquatic toxicologist to evaluate both freshwater and salt water effects. A workplace safety specialist to help choose PPE (personal protective equipment). An emergency responder to determine what to do if the stuff gets loose. And yes, a chemist to help with the physical properties. But, as a firm believer that the old regulations were insufficient to cause MSDSs to have even a modicum of relevant information I resisted writing that column. Certainly more information is good, isn’t it? Even if that information can’t easily be provided by just one chemist.
And then I saw this. Let me just type it in for you. “Understanding the Content of SDSs/eSDSs.” Okay, a good title about a relevant skill. It continued with “Online training course”. Well, of course, in these days of the coronaviruses and COVID-19, certainly the course needs to be online. And then the hammer, “(4 days)”. Huh, what? Four days? Seriously? I’m not sure I’d’ve signed up for it at four HOURS. That’s it. It’s official. We’ve gone too far and the pendulum has swung to an extreme. We seem to have forgotten who the SDS is written for. It’s not for the health & safety professional with a university degree, it’s for the people working with the materials. It’s for the people who may be exposed in the workplace as they make and package products. It’s for people who may not have finished their pre-university schooling, for people who don’t read well or don’t like to read so they got a job ‘doing’ instead of reading. It’s for people who don’t have the wherewithal to obtain information about the chemical materials in their work environment, so that they can protect themselves. The university educated health & safety professional can find the underlying data for themselves, or ask suppliers for more data so that minimum workplace safety standards can be put into place. But when all the extra information suitable for the safety professional is put into the SDS, it renders the document virtually unusable for those in the workplace who struggled to get through 10th year basic science classes.
In other words, if it takes four days, FOUR DAYS, (yeah, I’m still having trouble grasping that), to teach someone to get useful and usable information from an SDS, then it’s too damn complicated for the original target audience. I dunno, but from my porch swing it sure looks to me like the regulators have lost touch with the purpose of the document.