Under 29 CFR 1910.1200(d)(5) entitled Hazard Determination, OSHA indicates methods to determine the hazards associated with mixtures. This section indicates that if a mixture has been tested as a whole to determine its hazards (both health and physical), the results of that testing shall be used in determining whether the mixture is hazardous. For untested mixtures, OSHA indicates that the mixture has been assumed to present the same health hazards as do the components that comprise one (1%) percent or greater of the mixture (or 0.1% or greater for any carcinogens).

The testing required to determine if a mixture is hazardous or not would include Primary Eye Irritation with Rabbits, Primary Dermal Irritation with Rabbits, Oral LD50 with rats and Inhalation Toxicity LC50 with rats. Since the testing required to determine if a mixture is hazardous or not, is quite expensive, Quaker Chemical does not perform most of this testing on a routine basis.

For untested mixtures, the Safety, Health & Environmental Group (SHE) lists all hazardous ingredients that are contained in the mixture at 1% or greater(or 0.1% or greater if a carcinogen). If the ingredient is listed in one of the following sources, it is automatically listed on the Label/MSDS:

OSHA 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances
Threshold Limit Values for Chemical Substances and Physical Agents (ACGIH), current year
National Toxicology Program (NTP), Annual Report on Carcinogens, latest edition
International Agency for Research on Cancer (IARC) Monographs, latest editions

Each raw material is reviewed for the following information:

Chemical Name, if a single component
CAS Number
SARA 311/312 status
SARA 313 status
TSCA Inventory status
HMIS/NFPA Codes
Does the material have a TLV/TWA specified by the manufacturer?
What hazards are listed on the MSDS for the specific raw material? For example, does the supplier indicate that the material will cause severe eye irritation or that there is information that the material has been shown to cause delayed kidney/liver effects in animal testing?

All of this information is recorded in a database and is reviewed periodically as we receive updated MSDS’s from our suppliers. MSDS are placed on the imaging system and are maintained for thirty (30) years as required by OSHA.

The above information is then used to prepare a label/MSDS for each Quaker product. The ingredients listed will be those that are hazardous because they appear on one of the above lists or because of information received from the supplier (eye irritant, skin irritant, target organ effects, etc.). In addition, the flash point and pH listed on the formula are used to determine the physical hazards associated of the product and if the product must be labeled under the Department of Transportation regulations (49 CFR).

If you have any additional questions, please feel free to contact the Safety, Health & Environmental Group.

PREPARED BY: Kathryn F. Strang
Manager, Safety, Health & Environmental
May 15, 1997
610-832-4304

THIS INFORMATION IS FOR EDUCATIONAL PURPOSES ONLY.