I co-authored an SDS for several mixtures containing between 50% and 98% ethylene glycol. These are coolant/antifreeze products.
I included target organ toxicity statements and pictograms for kidney and liver damage because…well that’s what ethylene glycol does. I found a multitude of comparable product SDSs to make sure my designations were correct and I was not overstating the hazards nor omitting hazards.
I just received notice from the DLA that the SDSs are non-compliant with GHS and OSHA regulations describing those target organ toxicity statements as “extra”.
I cannot fathom how this is possible. The toxic effects of ethylene glycol are known…well known.
- It is known that prolonged exposure damages the kidneys and the liver.
- Every other manufacturer’s comparable product has the exact same wording and pictogram I am being told is unnecessary and non-compliant.
Please, can anyone provide any insight into this? They are claiming only the exclamation point “warning” for irritant and acute toxicity is required and I cannot find any comparable examples nor figure out how the chronic toxicity of ethylene glycol can be ignored.