It seems the games may never end with HFO-1234yf and it’s designation as a Highly Hazardous Chemical (HHC) within the Process Safety Management Standard. A friend of a friend in the automobile manufacturing industry contacted me about their use of this new refrigerant. The friend/client shared all of my previous articles explaining how HFO-1234yf is a PSM-covered chemical. But wait, the new SDS from one of the manufacturer’s no longer classifies the chemical as a Category 1 Flammable Gas; not that this has changed – it is still a CAT 1 Flammable Gas; the manufacturer simply changed their SDS and removed the wording Category 1. So the chemical is still a PSM chemical and the manufacturer is providing a NON-compliant SDS to its customers. For a global chemical manufacturer to make this error on the most basic safety document, they are responsible for it really makes me wonder what is going on!
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Mandatory Appendix D A safety data sheet (SDS) shall include the information specified in Table D.1 under the section number and heading indicated for sections 1-11 and 16. If no relevant information is found for any given subheading within a section, the SDS shall clearly indicate that no applicable information is available. Sections 12-15 may be included in the SDS, but are not mandatory.
1910.1200(d)(1) Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and, where appropriate, THE CATEGORY of each class that apply to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement. |
Here is Section 2 of the new SDS from the supplier: