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When supplied as pure (concentrate) hydrophilic emulsifiers (removers) are labelled as "Irritant" and even " Harmful", and Risk phrases comprise phrases such as "Harmful if swallowed", "Risk of serious damage to eyes", "Irritating to eyes", "Irritating to skin", etc.

 

Emulsifiers in tanks are diluted in water at concentrations depending on the applicable specifications/procedures as well as on the maximum concentration at which they are qualified in the QPL (Qualified Products List) annexed to the SAE-AMS 2644 specification.

 

More and more users put labels on the tanks of an FPI installation; the name of the product in the tank, what it is (a PE Level 4 penetrant, an hydrophilic emulsifier, etc.) are written, along Risk and Safety (R and S) phrases.

 

If writing on this label exactly the same R and S phrases that the supplier puts on the drum's label is right for penetrants and developers, luckily when diluting an hydrophilic emulsifier, it is likely that the R and S labelling shall be changed. For instance, if a pure product labelled as "Irritating to eyes" is diluted to 5% in water, it is very likely that NO LABELLING at all would be needed.

 

All the substances contributing to ''hazard'' phrases, i.e. those labelled as "Harmful", "Irritant", "dangerous for the environment", etc when pure, may not require any labelling, or at least a "lower grade" labelling. For instance a "Harmful" chemical may need only an "Irritant" labelling when diluted.

 

This is in line with the Section 2 ''Composition/information on ingredients'' of the Material Safety Data Sheets (MSDS), as per ISO 11014-1:1994 ''Safety data sheet for chemical products -- Part 1: Content and order of sections'' issued 1994.

In this Section 2 every constituent contributing to risk phrases shall be specified with the R phrases the pure constituent comply to.

 

But if this same constituent is used at a low concentration in the final product, the labels and symbols, the R and S phrases which are shown in Section 15 as it is on the drum, can, etc may not display the same risks as in Section 2.

 

This point is not well understood by many users:

 

- "Sir, in the MSDS Section 2, one of the constituents comes with a "Harmful" phrase, while on the label and in Section 15, the product is only "Irritant". There is some mistake somewhere!"

 

- "No, Sir, this is due to the low concentration of this ingredient in the product. For instance a 5% concentration ""lowers the rating"" from "Harmful" to "Irritant".

 

So when you, users, modify the product, for instance by diluting with water, ask the supplier what is the right label to affix on the tank.

 

To avoid any misunderstanding, especially regarding the hydrophilic emulsifier, it would be advisable that penetrant material suppliers/manufacturers state in Section 2 of the relevant MSDS that the risks phrases and label symbols are for the pure (undiluted) chemical only and that when diluted to the recommended strength of use, the product does not show these risks.

 

This same precaution is useful for water-based magnetic inks. Generally the concentrate is diluted at 2% in water. Very often, there is then NO NEED AT ALL for any R and S phrase, for any specific label!

 

HYDROPHILIC EMULSIFIERS LABELLING