Date: Sat Apr 17 1999 - 22:41:13 CDT
Part of the problem associated with the VOC and other pertinent environmental
information being placed on an MSDS is that OSHA does not require this
information. If it does not pertain to the health and/or safety concerns
associated with a given product and it does not fit the information
requirements as specified under the Hazard Communication Standard, then OSHA
can't do anything to enforce the data and/or its quality. It is important to
keep in mind that MSDSs are not environmental data sheets.
In order to resolve this problem, I would suggest two courses of action. The
first would be to contact the supplier and inform them that they have to
conduct a Method 24 analysis on the product to determine VOC content. While
there are some problems associated with Method 24 when it comes to low VOC or
high water-based materials, it is the only option. EPA is working on
modification to help resolve the problems with the method. The other step
would be to give the supplier a copy of the attached VOC/HAP data sheet and
have them complete it. If they fill in the blanks correctly, then they will
have run Method 24.
Good luck. I have had many heated discussions with suppliers on this subject.
There is a general lack of understanding in both the printer and supplier
community on this very important subject. In most instances, once both
parties are informed, then the correct information is generated.
Content-Disposition: inline; filename="VOCDATA.DOC"
VOC AND HAP DATA SHEET
PROPERTIES OF THE PRODUCTS "AS SUPPLIED" BY THE MANUFACTURER
Product Manufacturer ___________________________________________
Product Identification ____________________________________________
Properties of the product as supplied to the customer.
Product density __________ lb/gal. ASTM D1475-60
Total volatiles __________ Weight Percent ASTM D2369
Water content __________ Weight Percent ASTM D 4017
Organic volatiles __________ Weight Percent
VOC content __________ lb/gal.
Flashpoint __________ ASTM D93
HAP Content ___________ Method 311
Hazardous Air Pollutants:
Name Weight %
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