I appreciated Thomas P. Fuller's "Material Safety Data Sheets in Health Care" (Health and Safety, August), which reviewed the useful information that can be found in these documents. But it's important for nurses to know that there are some definite limitations to the information contained on a Material Safety Data Sheet (MSDS).
These documents are created by the manufacturer of the product and follow a format dictated by Occupational Safety and Health Administration (OSHA) standards. Manufacturers don't have to reveal safety data that isn't required by the OSHA-specified format. For instance, there's no requirement that the MSDS reveal any effects of chronic, low-dose exposure (for example, endocrine disruption or bioaccumulation). There's also no requirement that the MSDS be updated as new scientific information about the safety of the product becomes available. There's no requirement that the MSDS reveal the identity of proprietary ingredients.
An extreme example of the system failing to work occurred in April 2008, in Durango, Colorado, when an ED nurse fell ill after treating a gas field worker.1 Although many of the details are unknown—due to patient privacy laws and companies that cite the need to protect proprietary information—it's believed the nurse inhaled a chemical that was on the clothing of the gas field worker, a chemical that's pumped into natural gas wells to break the rocks and push the gas out. But neither she nor her health care providers could discover which chemical she was exposed to. The worker's company refused to reveal this proprietary information, so the physicians treating the nurse's eventual liver, heart, and respiratory failure had to guess which course of treatment would be best. She's recovering but doesn't know the long-term effects of this incident.
This nurse's experience, and the limitations of the information available on the MSDS, point to the necessity of nurses' involvement in reforming chemical policy regulation in the United States. The American Nurses Association supports legislative efforts—the Toxic Chemicals Safety Act (HR 5820) and the Safe Chemicals Act (S 3209)—to reform the Toxic Substances Control Act of 1976. We should also press OSHA to revise the standards for the MSDS, requiring frequent updating based on current scientific and field data, reporting of what's known about chronic, low-dose exposure, and limiting the amount of time a chemical can remain a trade secret.
Maye Thompson, PhD, RN
Environmental Health Program Director, Oregon Physicians for Social Responsibility, Portland, OR