3. (OSHA LOA 2013). Section 8 of the SDS requires the SDS preparer to include the applicable OSHA permissible exposure limits (PELs) and American Conference of Governmental Industrial Hygienists (ACGM) Threshold Limit Values (TLVs®). Must the PELs and TLVs® be included regardless of the concentration of the constituent or ingredient? Are they required if the ingredient does not contribute to the hazard classification? If the material has a TLV® and must be listed in Section 8, does it also have to be listed in Section 3
- Under Section 8 of Appendix D to the HCS 2012, subheading (a), the manufacturer must list the OSHA PEL, ACGIH TLV®, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. The requirement to include PELs and TLVs® in Section 8 of the SDS applies to any constituent or ingredient (including additives and impurities) that is present in the mixture or - substance above its cut-off value, or if it is below the cut-off value but still contributes to the hazard classification of the material. Please see the answer to question 8 for more details about contributing to the classification of the material. If a constituent is not present in the mixture or substance above its cut-off value, and does not contribute to the hazard classification of the substance or mixture, the PEL and TLV® associated with the ingredient need not be listed on the SDS. The lists of constituents in Sections 3 and 8 must be the same. If the constituent does not have a TLV® or PEL, its recommended exposure limit must be listed as "not applicable (N/A)" or "none."
4. What are "DERIVED NO EFFECT LEVEL" (DNEL)?
- The level of exposure above which humans should not be exposed. Used in REACH quantitative risk characterization and is established for the substance based on:
- Population: Workers, consumers and the general population (via environment)
- Route: Inhalation, dermal and ingestion exposure
- Duration: Acute (short-term) and chronic (long-term) exposure
- Effect: Systemic or local
- Derived for chemicals having a threshold mode of action
- Potential for many different DNELs because of different combinations and exposures
- A very good summary of this topic is found here
- Another good summary is found here
- The GESTIS DNEL Database has some values
5. In SDScribe™ , I notice that there are optional PPE Pictograms which can be selected in tab 8.2 Exposure-protection. Am I required to add these to my SDSs? And how do I replace the PPE pictograms with my own in-house ones?
- You are not required to display PPE pictograms.
- To replace the in-house versions with your own images, make sure the images have the same file name as the one that you want to replace (e.g., WP_gloves.jpg) and is located in this folder: C:\Hazard_Solutions\Database\Resources\Graphics
- To re-size the images from 30-150 pixels, enter a value in the text box. The default size if 48 pixels.