The Case for Product Testing
Under OSHA’s rules implementing the Globally Harmonized System of
authoring Safety Data Sheets and labels, formulators and SDS authors
now need to classify products for hazards. If critical test data – eye and
skin irritation and acute toxicity – are not available, a detailed
assessment of hazards based on the classifications of all included
components according to the GHS rules for mixtures must be
completed. Classification based on this approach may result in
“overclassification,” that is, a product concentrate classified as a skin
corrosive when, in fact, it is a skin irritant. While OSHA says testing is
not required, formulators may find it advantageous to test key products
and use “bridging principles” to extend application of key product
testing results to other products. With a target date of June 1, 2015, for all new SDSs and labels to be completed, much work needs to be
done – and quickly. Using examples and cost estimates, the case for
product testing will be reviewed.