15-0603 v3.X Red list Required Documentation

Question:

In reviewing the required basic documentation for Imperative 10: Red List, I10-2 Supporting Data states a 'complete Material Safety Data Sheet (MSDS)' is one of the three acceptable documents. What qualifies as a 'complete' MSDS sheet? The majority I am reviewing only list small percentages of contents (hazardous materials). In a recent discussion with a mentor on the topic, I was told that 'you can't trust an MSDS sheet to be complete' which leads me to believe that if the MSDS sheet doesn't contain a complete breakdown of all ingredients, I then need to request a complete manufacturer-supplied ingredient list. Please describe what qualifies as a 'complete MSDS sheet.'

Can I be certain that if red list chemicals are present in the product, they will be listed on an MSDS sheet?

If an MSDS sheet does not contain a 100% breakdown of the composition, is a manufacturer supplied list required?

Answer:

1. A complete MSDS must address 100% of ingredients per "Ingredients List" in the August 2014 v3.0 Materials Petal Handbook (MPH p 8). A manufacturer ingredient list is acceptable if it is a 100% listing of all ingredients.

2. If an MSDS or other ingredient list does not clearly list 100% of ingredients, then the team cannot be certain that Red List chemicals are not present. 

3. If an MSDS or other ingredient list does not clearly list 100% of ingredients, then the team and must do further research or find alternative documentation for I10-2 Supporting Data, such as a Declare ID number or Health Product Declaration with Full Disclosure of all Intentional Added Ingredients (MPH p16).


Post ID 2958

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