U.S. NIOSH Seeks Input on 4 IDLH Value Profile Documents

by Caroline Miller, CIH, CSP

The National Institute for Occupational Safety and Health (NIOSH) is inviting the public to provide input on four draft Immediately Dangerous to Life or Health (IDLH) Value Profile documents. The IDLH Value Profile documents are based on the Current Intelligence Bulletin (CIB) 66 – Derivation of Immediately Dangerous to Life or Health (IDLH) Values, published in 2013. The public has until June 19, 2017 to provide comments.

The four affected chemicals and their IDLH values are as follows:

  • Acetonitrile (CAS No. 75-05-8): 113 ppm (190 mg/m3)
  • Chloroacetonitrile (CAS No. 107-14-2): 11 ppm (33 mg/m3)
  • Methacrylonitrile (CAS No. 126-98-7): 4 ppm (11 mg/m3)
  • Nitrogen dioxide (CAS No. 10102-44-0): 11 ppm (21 mg/m3)

{ Recommended Action Items }

  • Review your inventory of substances to determine if your company uses any of the affected chemicals
  • Review your standard operating procedures and workplace practices to ensure that employees can escape should an IDLH atmosphere develop


Department of Health and Human Services, Centers for Disease Control and Prevention, NIOSH, Request for the Technical Review of 4 Draft Immediately Dangerous to Life or Health (IDLH) Value Profile Documents:



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Thailand’s Department of Industrial Works Invites Public Opinions on Hazardous Substance Act Amendment

by Nathan Kongprachaya

The Department of Industrial Works welcomes the public to offer feedback on the proposed amendment to the Hazardous Substance Act. Interested parties can submit their comment forms via email: or fax: +662 2024230 from May 11 to June 1, 2017.

A highlight of the proposed amendment is the addition of term, “Transit”. Currently, transportation of hazardous substances and mixtures through Thailand requires business operators to notify the competent authorities two times – when the goods are brought into the country and when the goods are taken out of the country. The proposal will also allow the responsible agencies to set out the notification procedures for the goods during “transit”.

It should be noted that since six authoritative agencies – Department of Agriculture, Department of Fisheries, Department of Livestock Development, Food and Drug Administration, Department of Industrial Works, and Department of Energy Business – oversee their respective list of hazardous substances, the notification procedures may differ from one agency to another.

Other highlights of the proposed amendment include exemptions of certain hazardous substances imported for research and development and the increased validity of license from five years to ten years.


The Department of Industrial Works: Proposed amendment to the Hazardous Substances Act and comment form (in Thai only):


{ Recommended Action Items }

  • Review how the proposed amendment may affect your company for those products/substances shipped into or out of Thailand as well as transported through the country
  • Submit comments, as noted in the announcement, by June 1, 2017

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Final Deadline June 1 for Submitting Spanish Poison Centre Notifications

By Susana Planas MunGavin

All hazardous mixtures classified under CLP being placed on the Spanish market must be notified to the National Poison Centre by June 1, 2017.  Notifications must be submitted in Spanish by the manufacturer, importer or supplier responsible for placing the mixture on the market. Documents shall be submitted online via the Enterprise Communication System (Sistema de Relación de Empresas (SRE)).

Required documentation includes:

  • Toxicological information sheet
  • Label as provided when placed on the market
  • Safety Data Sheet (SDS)

{ Recommended Action Items }

  • Determine if you ship hazardous products into Spain
  • Compile necessary documentation for submission using SRE
  • Submit proof of payment of the fee
  • Notify by the June 1, 2017 deadline

For more information, please see our previous blog article on this topic:


Order JUS/992/2015 is available on-line, in Spanish, at:

Toxicological Information Service (Servicio de Información Toxicológica – SIT):

Enterprise Communication System – SRE:




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U.S. – New York State First to Require Disclosure of Chemicals in Household Cleansers

by Caroline Miller, CIH, CSP and Nathan Kongprachaya

The New York State Department of Environmental Conservation (NYSDEC) has released a draft of the Household Cleansing Product Information Disclosure Program for public comment. The program will be the first in the United States to require manufacturers to divulge chemicals in household cleansing products that may adversely affect human health or the environment. Comments will be accepted until June 14, 2017.

Affected products include items such as surfactant-containing soaps and detergents “used primarily for domestic or commercial cleaning purposes, including but not limited to cleansing of fabrics, dishes, food utensils and household and commercial premises.”

Excluded from this program are foods, drugs, cosmetics and pesticides, as defined in the draft document. Certain commercial locations that will be included in the program are specified in the draft document.

The Cleansing Product Information Disclosure Certification Form must be submitted to the NYSDEC by manufacturers for all “domestic and commercial cleaning products distributed, sold, or offered for sale in New York State.”

In addition to the certification form, the program also includes a Guidance Document to assist manufacturers, which contains strict guidelines on how the manufacturer will provide the information to the consumers. There are other stringent rules in which manufacturers must follow to provide the disclosure.

The Guidance Document also includes information on how similar products may be handled under the disclosure. The information that is required to be disclosed includes items such as product and manufacturer information, ingredients, health and environmental effects, etc.

Provisions for Confidential Business Information (CBI) are provided and can be used to withhold ingredients from disclosure. Unless the manufacturer is claiming CBI, all ingredients intentionally included in a household cleanser, including trace amounts, must be disclosed.

The Guidance Document has also defined a list of “Chemicals of Concern” in which the manufacturer must disclose the ingredient, and may not withhold as CBI, if it is on any of the lists. Some of the “Chemicals of Concern” lists are:

  • The Association of Occupational and Environmental Clinics (AOEC) Asthmagen List;
  • International Agency for Research on Cancer (IARC) Carcinogen List;
  • E.U.: Endocrine Disruptor List, Substances of Very High Concern List;
  • U.S. Environmental Protection Agency (EPA): Chemical of Concern List, Persistent, Bioaccumulative, and Toxic (PBT) Chemicals List, Priority Chemicals List, Ozone Depleting List

The “Chemicals of Concern” additionally include chemicals that would be categorized under the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) as a skin corrosive/irritant, serious eye damage/irritant, respiratory or skin sensitizer, mutagen, or aquatic toxin.

The proposed program also requires the manufacturers to update the information each time the formulation of the product is changed, or a new product is available in the market. Moreover, the manufacturers will be required to review the information once every two years at a minimum, and update as necessary.

Complete details can be found on the NYSDEC site.

{ Recommended Action Items }

  • Review your household cleansing products, as defined in the program, that are distributed, sold/offered for sale, etc. in New York State
  • Review how the proposed program will affect ingredient disclosure for those products
  • Review all the Chemicals of Concern lists for those substances that cannot be claimed as CBI
  • Submit comments, as noted in the announcement, by June 14, 2017


NYS Governor Announces New Regulations to Require Disclosure of Chemicals in Household Cleaning Products:

NYSDEC Household Cleansing Product Information Disclosure Program:




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U.S. EPA Reopens Comment Periods on Two Proposed Rules

By John J. Kowalski, CHMM

On January 19, 2017, the U.S. Environmental Protection Agency (EPA or the Agency) published a proposed rule to prohibit the use of Trichloroethylene (TCE) in vapor degreasing and to establish certain other requirements. See our previous blog article entitled “U.S. EPA to Prohibit Trichloroethylene (TCE) Use in Vapor Degreasing,” which was posted on February 17, 2017, for additional information.

Also on January 19, 2017, EPA published a proposed rule to prohibit the use of Methylene chloride and N-Methylpyrrolidone (NMP) for consumer and most types of commercial paint and coating removal and to establish certain other requirements. See our previous blog article entitled “U.S. EPA to Prohibit Certain Uses of Methylene Chloride (MC) and N-Methylpyrrolidone (NMP),” which was posted on February 24, 2017, for additional information.

On May 1, 2017, the Agency reopened and extended the comment periods for both of these proposed rules. Under this extension, comments must be received on or before May 19, 2017.


Environmental Protection Agency. “Trichloroethylene; Regulation of Vapor Degreasing Under TSCA Section 6(a); Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain Uses Under TSCA Section 6(a); Reopening of Comment Periods.” Federal Register 82 (1 May 2017): 20310-20311.



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