The following articles were written by the late Mike Royko, and published in the Chicago Tribune on the dates indicated. These articles were in response to a message sent to Mr. Royko regarding MSDS's by Scott Logan.
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Date: Friday, April 12, 1996
Source: Mike Royko.
Copyright Chicago Tribune
OSHA MANAGES TO KEEP SPIGOT OF PAPERWORK OPEN
Most businessmen aren't fond of the federal agency known as OSHA, the Occupational Safety and Health Administration.
It's OSHA's job to make sure that people have safe working conditions. Which is good.
But businesses say that OSHA's bureaucrats sometimes get carried away and bombard them with silly paperwork.
A small Northwest Side manufacturer recently received a set of instructions from OSHA on how to safely handle a certain type of fluid.
It is known as a MSDS (Material Safety Data Sheet), and the owner of the company said: "Thought you might enjoy seeing this. Having dealt recently with the rather overzealous characters at OSHA, it does not surprise me that there is a MSDS for water."
That's right: water, the stuff that comes out of the kitchen faucet, the shower, and flushes down the toilet.
Space doesn't permit me to print the entire OSHA guideline for water. And some of it was such technical gibberish that only the most dedicated water freak could possibly appreciate it.
But here are some of the highlights.
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MSDS for Water
Product name: Water
Formula Wt: 18.00
Cas No.: 07732-18-5
Niosh/rtecs No.: ZC0110000
Common Synonyms: Dihydrogen Oxide
Product Codes: 4218,4219
Baker Saf-T-Data (TM) System:
Health - 0 None
Flammability - 0 None
Reactivity - 1 Slight
Contact - 0 None
Hazard Ratings are 0 TO 4 (0 = No Hazard; 4 = Extreme Hazard)
Laboratory Protective Equipment: Safety Glasses; Lab Coat
Storage: Keep in tightly closed container
Boiling Point: 100 C (212 F)
Vapor Pressure(MM HG): 17.5
Melting Point: 0 C (32 F)
Vapor Density (Air=1): N/A
Specific Gravity: 1.00
Evaporation Rate: N/A
Appearance & Odor: Odorless, clear colorless liquid
Fire and Explosion Hazard Data: Flash Point (Closed Cup) N/A
Flammable Limits: Upper - N/A; Lower - N/A
Fire Extinguishing Media: Use extinguishing media appropriate for surrounding fire.
Health Hazard Data:
Effects of Overexposure: No effects of overexposure were documented.
Target Organs: None Identified
Medical conditions generally aggravated by exposure: None identified
Hazardous Polymerization: Will not occur
Conditions to Avoid: None documented
Spill and Disposal Procedures: Dispose in accordance with all applicable federal, state and local environmental regulations.
Respiratory Protection: None Required
Special Precautions: Keep container tightly closed. Suitable for any general chemical storage area.
Water is considered a non-regulated product, but may react vigorously with some specific materials. Avoid contact with all materials until investigation shows substance is compatible. Protect from freezing.
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There was much more, twice as long, including information on how to transport water. You simply transport it, as any restaurant bus boy could tell them, although the bureaucrats made it sound like a major project.
But I have noticed a few flaws in OSHA's guidelines.
For example, under Health Hazard Data, the bureaucrats said: "Effects of Overexposure: No effects of overexposure were documented."
Well, these bureaucrats must lead sheltered lives. Obviously, they've never been around when the cops pull what is known as a "floater" out of the Chicago River or Lake Michigan.
A floater is someone who jumped, was pushed or stumbled into the water and was "overexposed" for a few hours, days or weeks. I've seen it, and the effects of "overexposure" are not something you want to chat about over breakfast.
And the bureaucrats also said: "Conditions to Avoid: None documented."
Nonsense. Among the conditions to avoid are these: Don't make the potentially deadly mistake of stepping into a cold shower when you expect the water to be warm.
And you don't mix water with gin, vodka, rum, beer, wine and many other beverages, although it's permissible and even advisable with bourbon, scotch, or (this is open to debate) fine Irish whiskey.
The owner of that small company also said: "We have even received MSDS' for `Hand Cleaner' used in our shop."
See? There was a time when people knew how to use soap and water to wash their hands when they went to the washroom.
Now the federal government gives us guidelines.
We've come a long way, booby.
Keywords: FEDERAL AGENCY
Document ID: S610312c
Date: Thursday, April 25, 1996
Source: Mike Royko.
Copyright Chicago Tribune
BLAMING BUREAUCRATS FOR SILLY DOCUMENT DOESN'T HOLD WATER
The federal officials at the Occupald me it was legitimate.
So I did a column about it, because it struck me as being kind of silly for a federal agency to be telling people about what water can and can't do.
A few days later, I got a call from a spokesperson for OSHA who said: "OSHA does not issue MSDS's for water. There is no such thing as an MSDS for water.
"We can understand people spoofing OSHA. We've had a whole year of this. When we deserve it, we deserve it, but here we don't. It goes against what OSHA stands for.
"Yes, there have been situations where overzealous OSHA inspectors have said someone needs an MSDS when they don't and a citation is issued, but they are extremely rare, given the tens of thousands of inspections we do."
I checked back with the businessman who had given me the MSDS, and I realized that I had goofed. From what he had said originally, I had assumed that he had received the MSDS from OSHA.
But it turned out he hadn't. Instead, he had been browsing through a university database that contains a voluminous listing of MSDS documents. And he had come across the one for water. So he got a copy of it and decided to pass it along to me.
"So I've been duped by a spoof," I said.
"No," he said, "I know an MSDS when I see one, and this one is legitimate."
So I started trying to track down the source of the water MSDS. But before I finished, there was another call from the OSHA spokesperson.
"Yes, the MSDS for water does exist. A company in New Jersey did an MSDS for every substance under the sun. We aren't the people who devised it. A lot of consultants advise companies on making MSDS's, telling them they need them for everything known to man. They make a lot of money doing that."
Then the spokesperson said that as a result of my column, some congressmen had just introduced a whimsical amendment withholding funds for any MSDS's on water, and the spokesperson bemoaned the anti-bureaucratic raps that OSHA endures.
"When this Congress started out, they were saying all sorts of things, like we killed the tooth fairy because we wouldn't let dentists give patients back their extracted teeth. Or that we think sand is poison. Or that we think chalk is poison. It has been endless.
"The standard that OSHA has is that if someone works with hazardous material, he has the right to know what is in it and the potential side effects. I talked about the consultants, but society is so lawsuit happy that manufacturers include (the MSDS's) with all substances to protect themselves.
"I've heard of MSDS's for bricks and that OSHA thought bricks and sand were poison and that we required them for lumber.
"Lumber in another form can be hazardous--wood dust can be hazardous if you breathe it. If you use sand for blasting, it becomes so fine that it can cause silicosis, which is cancer. But they said we think beaches are hazardous.
"It's a question of which criticism OSHA deserves and what we don't deserve."
Which is only fair, and in this case, OSHA didn't deserve the criticism and I apologize for my carelessness.
As for the water MSDS, a spokesman for the New Jersey firm that created it said:
"We're not the only company that has one of these on file. No, OSHA doesn't require an MSDS for water. But some customers want everything coming into their plants to have an MSDS. They want every last thing documented. "To meet that requirement, we make the MSDS, and we developed an MSDS for water.
"It gets to be a point where you say, `If that's what you want as a customer, we will do it for you.' "
So although OSHA wasn't at fault, the fact that some businesses actually pay consultants to create documents on the uses of water just shows how nervous the government and its regulations have made them.
Oh, well, I guess it creates employment. If you are a consultant.
Keywords: FEDERAL AGENCY WATER HAZARDOUS ANECDOTE
Document ID: S6116002