As we know, both OSHA’s PSM and EPA’s RMP rule require us to evaluate the hazardous effects of inadvertent mixing of different materials that could foreseeably occur. BOTH standards allow us to use our SDS to comply with 910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process. The problem is that many SDSs do not adequately address 1910.119(d)(1)(vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. The SDSs will tell us not to mix the material with general other classes of chemicals but we need to know WHAT WILL HAPPEN if we send our HHC/EHS to a WRONG TANK or it is involved with a material within a shared secondary containment. NOAA’s Chemical Reactivity Worksheet is an EXCELLENT tool that we can use to perform this evaluation.
