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# _archive-combined-files_sds_30k (7 files, 30,046 tokens)

# 10,048  _AI_Waste Disposal and Risk Assessment.md
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title: FloodLAMP Waste Disposal and Risk Assessment Analysis
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notes: Created by AI during archive preparation. **NOT HUMAN VERIFIED - MAY CONTAIN ERRORS** AI-generated analysis of FloodLAMP reagent waste disposal under federal RCRA and state regulations, review of the 2022 biological risk assessment, and review of the uFMEA (SOP-004-B). Source documents include: Reagent Concentrations reference, SDS files (TCEP, EDTA, Clorox Bleach, IPA 70%, Twist RNA Control), the FloodLAMP biological risk assessment (January 2022), and the uFMEA spreadsheet (SOP-004-B).
summary_short: The FloodLAMP Waste Disposal and Risk Assessment Analysis provides a chemical-by-chemical evaluation of whether FloodLAMP's testing reagents and waste streams constitute hazardous waste under federal RCRA and state regulations (California, Florida, Texas), reviews the 2022 biological risk assessment commissioned by FloodLAMP, and reviews the use-FMEA (uFMEA, SOP-004-B) document. Key findings: working-concentration solutions (1XISS, reaction mixes, PGS) are not hazardous waste; concentrated 100XIS stock may trigger RCRA D002 corrosivity due to NaOH; biological waste classification under state medical waste regulations is the primary regulatory concern.


CONTENT

## Opus 4.6 MAX - Response
### Prompt (Verbatim)
Okay, your task is to do an updated risk assessment and answer some key questions related to this work and the chemicals and reagents used by FloodLAMP during its COVID testing. So, the key question is how should our pilot sites have disposed of the used reagents? So, I had a PhD bioscientist research this multiple times and concluded that based on our concentrations and the chemicals involved including the TCEP, it was not considered hazardous waste and we could dispose of it in the trash. Is that true? We had sites based in California, Florida, and Texas. So, if you need to look up, you know, tell me what regulations bear on making these kinds of decisions. How should, you know, the question being, how should, you know, chemicals used in, yeah, chemicals used in this context be disposed of. And the, there were so there are two primary waste artifacts or waste, you know, physical things. One is the samples, the inactivated samples. The other is the spent reactions, you know, the completed reaction tubes which were, you know, small volumes usually, you know, PCR strip tubes. The samples were usually 1.5 or 5 mil tubes with one to five milliliters of the 1x inactivation saline solution, along with the swabs and the spines. Yeah. So, the other question is how should the unused concentrated reagents be disposed. You know, it's my understanding that like the PGS, the primer, guanidine, saline solution, could just be disposed of in the trash. The primers, the DNA, they're not hazardous. The other chemicals are in very small concentrations. Now the 100x inactivation saline solution, I was a little more concerned that at the higher concentration of TCEP that that should be disposed of other than just thrown in the trash. But I think that too was determined by our PhD scientist again after multiple iterations of research. But all that was pre AI to be to be safe. I don't have a write up of that assessment, unfortunately. But, but additionally, I do have a write up of this risk assessment. So the second component what I want you to do is to review this risk assessment. And I don't want you to reproduce, you know, a new version of it. It, you know, ultimately ended up it ended up not being useful for us. Because it just wasn't specific enough. It didn't make a final kind of assessment or give us any type of numerical quantification of the risk. And that's what I wanted. So we started to look at doing that. And that's what this UFMEA document is. Remind me and describe what UFMEA is, what it stands for, and what's involved with it. Okay, make sure in your response to not include any personally identifiable information, including the name of the person who did the risk assessment or their company name. I want to keep that totally out of your response. Okay, do all this.

**Files included in context window:**
- Reagent Concentrations.md
- uFMEA FloodLAMP.xlsx
- FloodLAMP risk assessment (January 2022).pdf
- project-description.md
- _archive-combined-files_sds.md


### Prompt (Cleaned)
Your task is to do an updated risk assessment and answer key questions related to the chemicals and reagents used by FloodLAMP during its COVID testing.

The key question is: how should our pilot sites have disposed of the used reagents? I had a PhD bioscientist research this multiple times and concluded that based on our concentrations and the chemicals involved, including TCEP, it was not considered hazardous waste and we could dispose of it in the trash. Is that true? We had sites in California, Florida, and Texas. Tell me what regulations bear on making these kinds of decisions.

There are two primary waste streams: (1) the inactivated samples — usually 1.5 or 5 mL tubes with one to five milliliters of the 1X Inactivation Saline Solution, along with the swabs and spines; and (2) the spent reaction tubes — completed reaction tubes which were small volumes, usually PCR strip tubes.

The other question is: how should the unused concentrated reagents be disposed? My understanding is that the PGS (primer-guanidine solution) could just be disposed of in the trash — the primers (DNA) are not hazardous, and the other chemicals are in very small concentrations. The 100X Inactivation Saline Solution concerned me more because of the higher concentration of TCEP. I think that too was determined by our PhD scientist, after multiple iterations of research, to be non-hazardous. But all of that was pre-AI and I don't have a write-up of that assessment.

Second component: I have a write-up of a biological risk assessment. Review it, but don't reproduce a new version. It ultimately wasn't useful for us because it wasn't specific enough — it didn't make a final assessment or give any numerical quantification of risk. That's what we wanted, so we started a uFMEA. Remind me what uFMEA is, what it stands for, and what's involved.

Do not include any personally identifiable information in your response, including the name of the person who did the risk assessment or their company name.

**Files included in context window:**
- Reagent Concentrations.md
- uFMEA FloodLAMP.xlsx
- FloodLAMP risk assessment (January 2022).pdf
- project-description.md
- _archive-combined-files_sds.md


### Part 1: Waste Disposal Assessment

##### The Two Primary Waste Streams

Based on the reagent concentrations document and the SDSs, FloodLAMP's testing produced two distinct physical waste streams:

**Waste Stream A: Inactivated Sample Tubes**
- 1.5 mL or 5 mL tubes containing 1-5 mL of 1X Inactivation Saline Solution (1XISS) + swabs
- Chemical composition: TCEP 2.5 mM, EDTA 1.0 mM, NaOH 11.5 mN (~0.0115 N), NaCl ~153 mM
- Also contained potentially biohazardous material (nasal swab specimens)

**Waste Stream B: Spent Reaction Tubes**
- PCR strip tubes with ~25 uL per reaction
- Chemical composition: LAMP primers at ~1X (sub-micromolar concentrations), guanidine-HCl ~43.6 mM, NEB colorimetric LAMP master mix components, plus 2 uL of inactivated sample

##### Chemical Hazardous Waste Analysis

The key regulatory framework is the federal **Resource Conservation and Recovery Act (RCRA)**, codified at **40 CFR Part 261**, which defines hazardous waste through two pathways:

1. **Listed wastes** (P-list, U-list, F-list, K-list): Specific chemicals or waste streams explicitly named
2. **Characteristic wastes**: Wastes exhibiting ignitability (D001), corrosivity (D002), reactivity (D003), or toxicity (D004-D043)

Here is the chemical-by-chemical analysis:

**TCEP (tris(2-carboxyethyl)phosphine hydrochloride, CAS 51805-45-9):**
- Not on the RCRA P-list or U-list of listed hazardous wastes
- The SDS classifies it as a corrosive solid (Skin Corr. 1B, Eye Dam. 1) and it ships as UN 3261, Class 8, Packing Group II
- As a neat solid, it is clearly a corrosive hazardous material
- However, the RCRA corrosivity characteristic (D002) for aqueous solutions triggers at pH <= 2.0 or pH >= 12.5
- At 2.5 mM in 1XISS (diluted 1:100 from the stock), this is a very low concentration in a saline solution buffered near neutral pH — it would not trigger the D002 corrosivity characteristic
- Not on the TCLP toxicity characteristic contaminant list (40 CFR 261.24)
- Not a SARA 302 or 313 reportable substance per the SDS

**EDTA (CAS 60-00-4):**
- Not on the RCRA P-list or U-list
- The SDS classifies it only as Category 4 acute inhalation toxicity and Category 2 eye irritation (as a powder)
- At 1.0 mM in aqueous solution, it poses negligible hazard
- Not on the TCLP toxicity characteristic list
- DOT: Not regulated for transport
- CWA reportable quantity is 5,000 lb — far above any volumes involved here

**NaOH:**
- At 1.15 N in the concentrated 100XIS, this could produce a pH above 12.5, potentially triggering D002
- At 11.5 mN (0.0115 N) in the 1XISS working solution, this is far too dilute to produce corrosive pH — the resulting solution would be near neutral
- Not on the TCLP list

**Guanidine-HCl:**
- Not on the RCRA P-list or U-list
- Classified as Category 4 oral and inhalation toxicity (H302, H332), skin irritation (H315), eye irritation (H319)
- At 95.2 mM in PGS stock, and ~43.6 mM in the reaction, these are relatively dilute concentrations
- Not on the TCLP toxicity characteristic contaminant list
- Would not trigger ignitability, corrosivity, or reactivity characteristics in aqueous solution at these concentrations

**LAMP Primers (synthetic oligonucleotides):**
- Synthetic DNA is not classified as hazardous waste under RCRA
- No CAS number listing, not regulated

**NEB Colorimetric LAMP Master Mix:**
- Commercial enzyme/buffer mixture; proprietary but contains standard molecular biology reagents (DNA polymerase, reverse transcriptase, dNTPs, MgSO4, phenol red). None of these are RCRA-listed or characteristic hazardous wastes at working concentrations

**Twist Synthetic RNA Control:**
- Non-hazardous per SDS; synthetic RNA in TE buffer at extremely low concentrations

##### Assessment: Was the PhD Scientist's Determination Correct?

**For the spent reaction tubes and 1XISS sample tubes: Yes, the determination was substantially correct.** At the working concentrations used in FloodLAMP's testing, none of the individual chemical components would trigger RCRA hazardous waste characteristics:

- No components are RCRA-listed wastes (P/U/F/K lists)
- The dilute aqueous solutions would not exhibit corrosivity (pH would be well within the 2.0-12.5 range)
- No ignitability, reactivity, or TCLP toxicity concerns at these concentrations
- The volumes are extremely small (microliters to low milliliters)

**However, there are important caveats:**

1. **Biohazardous waste is a separate question from chemical hazardous waste.** The CDC's November 2020 Lab Advisory explicitly stated that "laboratories and testing sites should treat all waste from suspected or confirmed COVID-19 patient specimens and kit components as biohazardous waste." While FloodLAMP's TCEP-EDTA + heat treatment protocol was designed to inactivate SARS-CoV-2 (and published literature supports its effectiveness), the CDC guidance applied a conservative "out of an abundance of caution" approach. The risk assessment document reviewed here also states that "since the validity of this process cannot be confirmed on every specimen, out of an abundance of caution, all samples should still be considered biohazardous."

2. **State-specific regulations may layer additional requirements:**

   - **California**: Has broader hazardous waste definitions than federal RCRA under Title 22 CCR. California recognizes corrosive solids (RCRA only covers liquids) and has additional "non-RCRA hazardous waste" categories. California DTSC also requires laboratory hazardous waste determinations. However, even under California's stricter criteria, the working dilutions (1XISS at 2.5 mM TCEP, reaction mixes at ~44 mM guanidine-HCl) would not meet the corrosivity pH threshold. The bigger issue in California would be whether the waste is classified as medical waste under the Medical Waste Management Act.

   - **Texas**: The Texas Commission on Environmental Quality (TCEQ) published specific guidance for COVID-19 rapid testing kit disposal from schools, classifying testing waste as regulated medical waste requiring segregation from regular garbage, biohazard containers, and disposal at TCEQ-authorized facilities. This applies to the biological component, not the chemical component.

   - **Florida**: Florida DEP administers RCRA under state authorization. The Florida Department of Health has authority over biomedical waste. COVID testing waste would fall under biomedical waste regulations.

3. **The practical reality**: For small-volume, dilute laboratory waste from point-of-care COVID testing at these concentrations, the chemical component does not constitute RCRA hazardous waste. The biological component (potentially infectious specimens) is where the regulatory burden lies, and that is governed by medical/biomedical waste regulations at the state level, plus CDC and OSHA guidance, not RCRA.

##### The 100X Inactivation Solution (Concentrated Stock)

The instinct to be more cautious about the concentrated 100XIS was well-placed. At stock concentration:

- **TCEP at 0.25 M**: This is a concentrated corrosive substance. The SDS classifies neat TCEP as causing severe skin burns and eye damage.
- **NaOH at 1.15 N**: An aqueous solution at this normality would have a pH well above 12.5, **triggering the D002 corrosivity characteristic**.
- **EDTA at 0.1 M**: Less concerning but still at meaningful concentration.

**The concentrated 100XIS, if disposed of undiluted, would likely qualify as D002 corrosive hazardous waste** due to the NaOH concentration pushing pH above 12.5. This would require disposal as hazardous waste, not regular trash.

However, if only small volumes (a few milliliters in 5 mL vials) were being disposed, this raises the question of generator status. Facilities generating less than 220 pounds (~100 kg) of hazardous waste per month qualify as **Conditionally Exempt Small Quantity Generators (CESQGs)** under federal RCRA, which have reduced regulatory requirements. At FloodLAMP's operational scale, the total volume of concentrated 100XIS being discarded would have been very small.

**For the PGS (Primer-Guanidine Solution)**: At 95.2 mM guanidine-HCl in aqueous solution, this would not trigger corrosivity (neutral pH range) or other RCRA characteristics. The primers are non-hazardous synthetic DNA. Disposal in regular trash is defensible.

##### Summary Table: Disposal Recommendations

| Waste Stream | Chemical Hazard? | Biological Hazard? | Recommended Disposal |
|---|---|---|---|
| Spent reaction tubes (25 uL) | No (too dilute) | Low (post-inactivation) but CDC recommended treating as biohazardous | Biohazardous waste stream per state medical waste regs; chemical component is non-hazardous |
| 1XISS sample tubes (1-5 mL) | No (too dilute) | Moderate (specimens, even if inactivated) | Biohazardous waste stream per state medical waste regs; chemical component is non-hazardous |
| Unused concentrated 100XIS | **Yes** — D002 corrosivity likely due to NaOH pH >12.5 | No | Chemical hazardous waste (but very small quantities; CESQG rules likely apply) |
| Unused PGS stock | No | No | Regular trash acceptable |
|||

##### Relevant Regulations Summary

| Regulation | Jurisdiction | Relevance |
|---|---|---|
| RCRA (40 CFR 261-262) | Federal | Hazardous waste characteristics and generator requirements |
| OSHA Bloodborne Pathogen Standard (29 CFR 1910.1030) | Federal | Handling of potentially infectious materials |
| CDC Lab Advisory (Nov 2020) | Federal guidance | COVID POC testing waste as biohazardous |
| DOT 49 CFR 173.199 | Federal | Transport of Category B infectious substances (UN3373) |
| California Title 22 CCR Div. 4.5 | CA | Broader hazardous waste definitions; Medical Waste Management Act |
| TCEQ Rules, 30 TAC Chapter 326 | TX | Medical waste management |
| Florida Biomedical Waste regulations (Chapter 64E-16 FAC) | FL | Biomedical waste handling and disposal |
|||


### Part 2: Review of the Risk Assessment

The risk assessment document (dated January 2022) is a qualitative biological risk assessment focused on worker safety during FloodLAMP's point-of-care surveillance testing. Here is the review:

**What it does well:**
- Properly identifies the three main hazard categories: biological, chemical, and physical
- Correctly structures the analysis around the testing workflow stages (collection, initial processing, NAAT preparation, waste disposal)
- Appropriately references the NIOSH Hierarchy of Controls framework
- Provides a reasonable comparison table of FloodLAMP's test versus other POC diagnostic/screening tests
- Correctly identifies that FloodLAMP's self-collection model eliminates the highest-risk step (direct worker contact with potentially infected individuals)
- References relevant CDC, WHO, and APHL guidance documents

**What it lacks (and why it was found insufficient):**
- **No numerical risk quantification**: It identifies hazards and describes mitigations but never assigns severity scores, probability estimates, or any numerical risk metric
- **No prioritization**: Without quantification, there is no way to rank which risks are most important to address
- **No residual risk assessment**: It does not evaluate whether the mitigations FloodLAMP implemented actually reduced risk to an acceptable level
- **Generic rather than specific**: The mitigations listed are broadly applicable to any COVID POC test, not specifically tailored to FloodLAMP's particular protocol and reagent set
- **No chemical risk quantification**: While it mentions chemical hazards (TCEP, EDTA, guanidine), it does not analyze concentrations, exposure levels, or compare them to regulatory thresholds
- **No waste disposal analysis**: The waste disposal section discusses biological contamination risks but does not analyze the chemical waste disposal question at all
- **Essentially a literature review with a comparison**: It reads more like a biosafety literature review and comparison document than an actionable risk assessment tool

The document's value was as a general biosafety framing document, but it did not meet the need for a specific, quantified risk assessment with actionable conclusions.


### Part 3: The uFMEA Document

##### What is uFMEA?

**uFMEA** stands for **Use Failure Mode and Effects Analysis**. It is a specialized variant of the traditional FMEA methodology adapted specifically for analyzing use-related risks — that is, risks arising from how users interact with a device, product, or system rather than from inherent design or manufacturing defects.

**Traditional FMEA** (sometimes called dFMEA for "design" or pFMEA for "process") has been a staple of quality engineering since the 1940s-1960s (originating with the U.S. military and later adopted extensively by the automotive and aerospace industries). It systematically identifies:
- **Failure modes**: What can go wrong?
- **Effects**: What happens if it goes wrong?
- **Causes**: Why would it go wrong?

**uFMEA** extends this by focusing specifically on the human-device interface — how users might misuse, misunderstand, or make errors when operating a product. It is particularly important for medical devices and in-vitro diagnostics, where the FDA requires human factors analysis as part of the design validation process under:
- **IEC 62366-1** (Application of usability engineering to medical devices)
- **ISO 14971** (Application of risk management to medical devices)
- **FDA Human Factors guidance** for premarket submissions

##### The Scoring System

The uFMEA uses three numerical ratings on a 1-5 scale, as defined in the "Change History" sheet of the document:

1. **Severity (SEV)**: Impact of the failure on the user or patient
   - 5 = Catastrophic (loss of limb, life-threatening)
   - 4 = Critical (severe long-term injury, potential disability)
   - 3 = Serious (short-term injury requiring additional medical intervention)
   - 2 = Minor (slight inconvenience, little effect on performance)
   - 1 = Negligible (no or negligible risk)

2. **Occurrence/Probability (OCC)**: How likely the failure is
   - 5 = Frequent (>= 1 in 100)
   - 4 = Probable (< 1 in 1,000)
   - 3 = Occasional (< 1 in 10,000)
   - 2 = Remote (< 1 in 100,000)
   - 1 = Improbable (< 1 in 1,000,000)

3. **Detection (DET)**: How likely the failure will be detected before it causes harm
   - 5 = Remote chance of detection (very high likelihood failure reaches patient)
   - 4 = Low chance of detection
   - 3 = Moderate chance of detection
   - 2 = High chance of detection
   - 1 = Very high chance of detection

The **Risk Priority Number (RPN)** = Severity x Occurrence x Detection. Higher RPN = higher priority for risk mitigation. After mitigations are applied, a **residual RPN (rRPN)** is calculated.

##### Review of FloodLAMP's uFMEA

The document (SOP-004-B, Version 0, effective 2021-11-23) covers 11 risk categories (U-1 through U-11) spanning the full testing workflow:

| Risk ID | Category | Entries |
|---|---|---|
| U-1 | Preparation | 11 failure modes |
| U-2 | Transport, Storage, and Handling | 8 failure modes |
| U-3 | Transport, Storage, and Handling (Primers) | 1 failure mode |
| U-4 | Reading the IFU | 1 failure mode |
| U-5 | Sample Preparation | 7 failure modes |
| U-6 | Sample Inactivation | 7 failure modes |
| U-7 | CLAMP Reaction Preparation | 7 failure modes |
| U-8 | Sample Addition and Heating | 7 failure modes |
| U-9 | Results Interpretation | 2 failure modes |
| U-10 | Waste Disposal | 3 failure modes |
| U-11 | Maintenance | 1 failure mode |
|||

**Positive aspects:**
- It uses the correct uFMEA framework with SEV/OCC/DET scoring and RPN calculation
- It covers the testing workflow comprehensively from preparation through waste disposal
- It identifies a wide range of realistic user errors (pipetting errors, temperature errors, contamination, etc.)
- It identifies current controls for each failure mode (IFU, training, SOPs, QC checks)
- It properly includes columns for post-mitigation scores and residual RPN

**Issues and limitations:**
- **Incomplete**: The "Actions Taken" and revised score columns (revised SEV, OCC, DET, rRPN) are all empty. This means the document only captures the pre-mitigation risk assessment. Without completed residual risk scores, the uFMEA does not demonstrate that risks have been reduced to acceptable levels.
- **RPN formulas not evaluated**: The RPN column contains Excel PRODUCT formulas rather than calculated values, suggesting this was a working draft.
- **Relatively narrow severity range**: Most failure modes are scored at Severity 2 (Minor) or 4 (Critical), with very few at 3 (Serious) and none at 5 (Catastrophic). For a surveillance test (not a diagnostic), severity 4 may be over-assigned for delayed diagnosis scenarios.
- **Waste disposal section is thin**: Only 3 failure modes for waste disposal (U-10), and they focus on biological contamination risk (opening tubes post-amplification, removing seals), not on chemical waste disposal. There is one entry about "hazardous chemicals/bio-hazardous materials" but it does not break down the specific chemical disposal considerations.
- **No risk acceptability criteria defined in this document**: While the scoring scales are defined, there is no stated threshold for what RPN level is acceptable vs. requires action (e.g., "RPNs above 24 require mitigation").
- **Version 0**: This is explicitly the first version — a starting point that was never completed or iterated on.

The document represents a solid structural foundation for a uFMEA but is essentially an incomplete working draft — consistent with the assessment that it did not meet the need for a specific, quantified risk assessment with actionable conclusions.


### Summary

The PhD scientist's conclusion about the dilute working solutions being non-hazardous waste from a chemical standpoint was well-founded. The concentrated 100XIS stock warranted more caution due to the NaOH-driven corrosivity, though the small volumes involved likely placed sites well within CESQG thresholds. The more operationally significant waste classification question was always the biological side — state-level medical/biomedical waste regulations — not the chemical side. The risk assessment provided a useful qualitative overview but lacked the quantitative teeth needed, and the uFMEA was structurally correct but never completed beyond Version 0.

## ChatGPT 5.2 Pro Extended - Response
Here’s what I’m going to do in this response: (1) answer the “trash vs regulated waste” questions for **used** and **unused** FloodLAMP reagents using the concentrations you provided, (2) cite the **federal + CA/FL/TX** rules that govern those decisions, and (3) review why the older narrative risk assessment wasn’t giving you the quantitative output you wanted and explain **uFMEA**.

### 1) Key disposal question: “Could used FloodLAMP reagents go in the trash?”

#### The short, practical answer

* **Used/inactivated sample tubes + swabs** and **spent reaction tubes** are **very unlikely to be “hazardous waste” under RCRA based on chemical characteristics** at the working concentrations you described (especially compared to corrosivity thresholds).
* But “not RCRA-hazardous chemically” is **not the same thing** as “OK for regular trash.” Whether **regular trash** was acceptable also depends on:

  1. whether the waste is considered **regulated medical/biomedical waste** in that state and setting, and
  2. whether you’re putting **free liquids** into municipal solid waste (often restricted by local landfill rules even when nonhazardous).

So the PhD bioscientist’s conclusion can be **directionally correct for the *used, diluted* waste from a chemical-hazard standpoint**, but it’s **not a complete disposal determination** unless it also covered medical/biomedical waste rules and practical solid-waste restrictions.

---

### 2) The chemical side: when is it “hazardous waste” (RCRA / state hazardous waste)?

#### The controlling concept

Under federal rules, the **generator** must make a hazardous waste determination **at the point of waste generation, before any dilution or mixing**, using knowledge and/or testing. ([Legal Information Institute][1])

A key “gotcha” for FloodLAMP is corrosivity:

* A waste is corrosive (and therefore hazardous, **D002**) if it’s aqueous and **pH ≤ 2 or ≥ 12.5**. ([Legal Information Institute][2])
  California uses the same pH threshold for corrosivity. ([Legal Information Institute][3])

#### Apply that to your actual FloodLAMP compositions

From your concentrations reference:

* **100X Inactivation Solution (100XIS)**: **TCEP 0.25 M, EDTA 0.1 M, NaOH 1.15 N**.
* **1X Inactivation Saline Solution (1XISS)** (from 1:100 dilution): **TCEP 2.5 mM, EDTA 1.0 mM, NaOH 0.0115 N**, plus ~0.9% saline. Primer‑Guanidine Solution)**: **guanidine‑HCl 95.2 mM + primers**.
* **Final reaction**: guanidine‑HCl ~**43.6 miluted into the 25 µL reaction).

##### What that implies (1XISS + swab + specimen)**

* Chemically: the NaOH is **orders of magnitude lower than the 100X l pH testing shows ≥12.5, it’s **unlikely to be D002 corrosive**. The conservative way to remove doubt is to **measure pH of a representative “worst-case” waste sample** (freshly made 1XISS + typical specimen load). The corrosivity threshold is the regulatory line. ([Legal Information Institute][2])
* So, **chemically**: often **non‑hazardous**.

**B) Used reaction tubes (spent amplification strips)**

* Chemically: ~43.6 mM guanidine-HCl and buffers/enzymes, tiny volumes.
* This is **not a listed RCRA waste**, and typically doesn’t meet RCRA characteristics (ignitable/corrosive/reactive/toxic) at those concentrations. (RCRA toxicity is a specific list of contaminan’t one of the classic D‑list metals/organics.) ([Legal Information Institute][1])

**C) Unused concentrates (this is where the conclusion often flips)**
This is the biggest regulatory trap in what you described:

* If you discard **unused 100XIS** (TCEP 0.25 M + **NaOH 1.15 N**), you must classify it **as discarded**, **before** diluting it. ([Legal Information Institute][1])
* A solution containing ~1 N NaOH is **very likely pH ≥ 12.5** → corrosive characteristic (**D002**) under federal rules, and the same pH threshold exists in CA. ([Legal Information Institute][2])

**Bottom line (chemical regulatory view):**

* **Used 1XISS/specimen waste + spent reactions**: *likely* **not RCRA hazardous** chemically (but verify pH if you want high confidence).
* **Unused 100XIS**: *likely* **hazardous waste (corrosive, D002)** → **not** appropriate for regular trash.

---

### 3) The biomedical/medical waste side (often the real “trash vs not trash” determinant)

Even if a waste is **not** chemically hazardous, it may still be regulated as **medical/biomedical waste** depending on state definitions and what kind of facility is generating it.

#### California (Medical Waste Management Act)

Two key points from the statute:

* **Saliva, sputum, nasal secretions** (and similar) are **generally not medical waste unless visibly contaminated with blood**. ([California Department of Public Health][4])
* If waste *is* “medical waste,” California requires it to be **treated** by specified methods (incineration, steam sterilization/autoclave, or approved alternatives) **prior to disposal as solid waste**. ([California Department of Public Health][4])

Implication for your CA pilot sites:

* If your waste was **nasal/saliva material without visible blood**, CA law provides a pathway where it may **not** be regulated medical waste. ([California Department of Public Health][4])
* But if your program (or a local enforcing agency) treats these as laboratory/diagnostic wastes associated with a communicable disease, they may require a regulated stream anyway (this is where local interpretation and the site’s classification matter).

#### Florida (Chapter 64E‑16)

Florida’s definitions mirror CA in a surprising way:

* “Body excretions… and secretions such as **nasal discharges, saliva, sputum** … **shall not be considered biomedical waste unless visibly contaminated with blood**.” ([Florida Department of Health][5])
* But “biomedical waste” also includes “**laboratory… wastes which contain human disease-causing agents**,” plus sharps, etc. ([Florida Department of Health][5])
  If it is biomedical waste, Florida has detailed **containment/labeling/treatment** requirements (e.g., red bags, sealed packages, treatment prior to disposal, etc.). ([Florida Department of Health][5])

A particularly relevant rule: **biomedical waste mixed with hazardous waste must be managed as hazardous waste**. ([Florida Department of Health][5])
That’s a strong reason to keep **unused 100XIS** out of any biomedical-waste stream.

#### Texas (TCEQ / TAC framework)

Texas defines “medical waste” more narrowly as special waste from health care-related facilities comprised of categories like:

* **bulk human blood/body fluids**, microbiological waste, pathological waste, sharps, etc. ([TCEQ][6])

Texas guidance also emphasizes that **treated medical waste** can be managed as municipal solid waste under specified conditions, and Texas rules include “thermal inactivation” as a recognized treatment method in their health-services rules. ([TCEQ][7])

Implication:

* Small-volume swab tubes (1–5 mL) may or may not be treated as “bulk body fluids” depending on definitions and accumulation practices, and facility classification matters. ([TCEQ][6])

---

### 4) So—how *should* your pilot sites have disposed of the two primary waste streams?

I’ll give you a **best-practice, compliance-robust** answer first, then note where the statutes create flexibility.

#### Waste stream A: inactivated specimen tubes (swab + 1–5 mL of 1XISS)

**Most compliance‑robust approach across CA/FL/TX:**

1. Keep tubes **closed** and place in a **leak‑resistant secondary container** (zip bag or rigid biohazard container), with absorbent if there’s meaningful free liquid risk.
2. Manage as **biomedical/medical waste** (or at least as “potentially infectious diagnostic waste”) via the site’s medical-waste program or a contracted hauler—especially if the site is operating in a “laboratory” posture or under CLIA-like governance.

**Why this is conservative:** even though CA and FL exclude saliva/nasal secretions unless visibly bloody ([California Department of Public Health][4]), the broader “laboratory waste/human disease-causing agents” language can pull diagnostic testing operations into biomedical waste rules depending on interpretation. ([Florida Department of Health][5])

**Where “regular trash” can be defensible:**

* If the specimens are **saliva/nasal secretions without visible blood** and you have a documented basis that they are not regulated medical/biomedical waste under that state’s definition (CA and FL explicitly carve these out). ([California Department of Public Health][4])
* And the waste is not chemically hazardous (e.g., not corrosive by pH). ([Legal Information Institute][2])
* And you prevent leakage/free liquids.

#### Waste stream B: spent reaction tubes (PCR strips, ~25 µL, post‑amplification)

Chemically, these are extremely small-volume aqueous mixes with guanidine-HCl at ~43.6 mM and master mix components.

**Best practice** is to dispose them in the same controlled waste stream as sample tubes (sealed, leak-resistant), because they:

* contained human specimen aliquots, and
* contain amplified nucleic acid (contamination control reasons).

Whether they legally must be regulated medical waste depends on the same state-specific definitions above; but operationally, treating them as controlled lab waste is cleaner.

---

### 5) The separate question: “How should unused concentrated reagents be disposed?”

### Unused 100X Inactivation Solution (100XIS)

This is the one I would *not* be comfortable calling “trash safe.”

* Composition includes **NaOH 1.15 N**.
* Hazardous waste determinations must be made **before** dilution/mixing. ([Legal Information Institute][1])
* If the pH is ≥12.5, it is **corrosive hazardous waste (D002)**. ([Legal Information Institute][2])

**Recommended disposal posture:**

* Treat unused 100XIS as **hazardous chemical waste (corrosive)** unless you have actual pH testing demonstrating otherwise.
* Do **not** put it in regular trash.
* Do **not** dump to drain unless your site has an EHS-approved neutralization/sewer-discharge procedure and the local sewer authority permits it.

### Unused PGS (guanidine‑HCl ~95.2 mM + primers)

* PGS is **not obviously RCRA-hazardous** at that concentration based on typical characteristics (not ignitable, not likely corrosive, not a D-list toxicant).
* But: it’s still a chemical solution. The “right” answer is often **drain disposal with plenowed by local sewer rules*, or collecting as **nonhazardous lab chemical waste**.

If PGS is contaminated with human specimens, then handle it under your biomedical waste logic.

### Primers / DNA

As you noted, primers/DNA themselves are generally not hazardous. The disposal question is usually about the **matrix** they’re in (buffer, salts, any hazardous additives).

---

### 6) What regulations bear on these decisions (the “decision tree” inputs)

### Federal hazardous waste (RCRA)

* Generator must make a hazardous waste determination **at the point of generation, before dilution/mixing**, and keep supporting records. ([Legal Information Institute][1])
* Corrosivity chered by **pH ≤2 or ≥12.5** (D002). ([Legal Information Institute][2])

### California

* California hazardous waste corrosivity threshold mirrors federal (pH ≤2 or ≥12.5). ([Legal Information Institute][3])
* California Medical Waste Management Act contains both:

  * the explicit exclusion for saliva/nasal secretions unless visibly bloody ([California Department of Public Health][4]), and
  * treatment requirements if something is medical waste. ([California Department of Public Health][4])

### Florida

* Florida biomedical waste definitions (including the nasal/saliva exclusion unless blood) ([Florida Department of Health][5])
* Packaging/containment/treatment requirements if waste is biomedical waste ([Florida Department of Health][5])
* Mixing biomedical waste with hazardous waste → manage as hazardous waste ([Florida Department of Health][5])

### Texas

* Texas definition of medical waste (categories; includes bulk blood/body fluids, microbiological wa([TCEQ][6])
* Texas rules/guidance on treatment options including thermal inactivation and on disposal as municipal solid waste when treated and documented ([Legal Information Institute][8])

---

### 7) Review of the older narrative risk assessment you shared (why it didn’t meet your need)

Without repeating any identifying names, here’s what the document does well and why it didn’t give you the “final numeric answer” you wanted:

#### What it does well

* It’s a solid **hazard identification** document for a point-of-care molecular workflow: it calls out the higher-risk steps (specimen handling, pipetting, potential aerosols/splashes, heat steps, disinfectants) and groups mitigations under the **Hierarchy of Controls** framework (elimination → engineering → administrative → PPE).
* It explicitly recognizes that “inactivation” steps can fail and recommends conservative handling assumptions.

#### Why it wasn’t operationally useful for your “so what do we do?” questions

* It’s primarily **qualitative**, not quantitative. It doesn’t produce:

  * a severity/occurrence/detectability scoring model,
  * an overall residual-risk rating, or
  * a prioritized list of “top risks” with numeric justification.
* It stays relatively **high level** on some operational questions (like waste handling/disposal), describing the hazard category but not making a specific classification decision (e.g., “this is regulated medical waste in CA/FL/TX” vs “this can be disposed as solid waste if X and Y are met”).
* It mixes **biosafety** and **chemical safety** concerns, but doesn’t do a concentration-driven waste determination (e.g., the difference between discarding **100X** vs **1X** solutions).

---

### 8) What uFMEA is (what it stands for and what’s involved)

**uFMEA** most commonly means **Use Failure Modes and Effects Analysis** (often also described as **User FMEA**). It’s an FMEA variant focused on **use-related hazards**—what can go wrong when real users perform tasks in real environments. ([Emergo by UL][9])

#### What’s involved in a uFMEA

A uFMEA typically follows this structure:

1. **Define the use process / user tasks**

   * Break the workflow into steps a user performs (collect sample, add reagent, cap tube, heat, load strip, interpret result, dispose waste, etc.).

2. **Identify potential failure modes (“use errors” / “task failures”)**

   * Examples: wrong volume, wrong tube, skipped step, opened tube at the wrong time, mislabeled sample, incorrect disposal, etc.

3. **Identify the effects and harms**

   * Not just “test fails,” but the **harm**: false negative → infected person not isolated; chemical burn; exposure; cross-contamination; etc.

4. **Score risk**

   * Classic FMEA uses ordinal ratings for:

     * **Severity (S)**
     * **Occurrence (O)** (or probability)
     * **Detection (D)** (how likely the failure is caught before harm)
   * Then computes a **Risk Priority Number (RPN = S × O × D)** to prioritize mitigations. ([ASQ][10])

5. **List current controls**

   * Training, labeling, physical constraints, packaging, SOPs, engineered guards, timers, etc.

6. **Define and implement additional actions**

   * And then re-score **residual risk** after controls.

#### Why uFMEA would have been the right move for your complaint

Your complaint about the narrative risk assessment was essentially: “I need **numerical prioritization and a residual risk statement**.” That’s exactly what an FMEA/uFMEA is designed to produce: a prioritized list of failure modes with **quantified (ordinal) risk scores** and a clear “before vs after controls” view.

One important caveat: RPNs are great for **prioritization**, but they are not a perfect measure of absolute risk (the scoring scales and definitions really matter). Many teams pair uFMEA with an explicit **risk acceptability matrix** (e.g., severity × probability) so you can say “acceptable vs not acceptable” rather than only ranking.

---

### A clean “answer” to your original claim

If I translate your PhD scientist’s conclusion into two separate claims:

1. **“Used FloodLAMP tubes are not hazardous waste (chemical).”**
   That is **plausibly true** for the *used, diluted* waste streams (1XISS + specimen, and spent reactions), because they’re unlikely to meet RCRA characteristics like corrosivity at working strength. The way to make this high-confidence is to document the determination basis under the generator rules and (if needed) verify pH. ([Legal Information Institute][1])

2. **“Therefore we can dispose in regular trash.”**
   That is **not automatically true**, because it also depends on (a) state biomedical/medical waste definitions and facility context, and (b) practical solid-waste rules about free liquids. CA and FL explicitly exclude saliva/nasal secretions unless visibly bloody ([California Department of Public Health][4]), which can support a “trash is allowed” pathway in some circumstances, but it’s still a site- and program-specific determination.

And separately:

3. **“Unused 100X inactivation solution can go in trash.”**
   This is the one that is **very likely false**: the **NaOH 1.15 N** stock is likely corrosive and hazardous (D002), and the hazardous waste determination must be made before dilution.  ([Legal Information Institute][1])

If you want, I can also turn this into a one-page “waste determination memo” template (no names, no company identifiers) that a pilot site could have kept on file: waste streams, compositions, hazard characteristics check, state medical waste decision, and final disposal route.



[1]: https://www.law.cornell.edu/cfr/text/40/262.11 "https://www.law.cornell.edu/cfr/text/40/262.11"
[2]: https://www.law.cornell.edu/cfr/text/40/261.22 "https://www.law.cornell.edu/cfr/text/40/261.22"
[3]: https://www.law.cornell.edu/regulations/california/22-CCR-66261.22 "Cal. Code Regs. Tit. 22, § 66261.22 - Characteristic of Corrosivity | State Regulations | US Law | LII / Legal Information Institute"
[4]: https://www.cdph.ca.gov/programs/ceh/drsem/cdph%20document%20library/emb/medicalwaste/medicalwastemanagementact.pdf "https://www.cdph.ca.gov/programs/ceh/drsem/cdph%20document%20library/emb/medicalwaste/medicalwastemanagementact.pdf"
[5]: https://www.floridahealth.gov/wp-content/uploads/2025/08/64E-16.pdf "https://www.floridahealth.gov/wp-content/uploads/2025/08/64E-16.pdf"
[6]: https://www.tceq.texas.gov/permitting/waste_permits/msw_permits/medwaste/medwaste-def?utm_source=chatgpt.com "What is Medical Waste?"
[7]: https://www.tceq.texas.gov/permitting/waste_permits/msw_permits/medwaste/medwaste-disposal "https://www.tceq.texas.gov/permitting/waste_permits/msw_permits/medwaste/medwaste-disposal"
[8]: https://www.law.cornell.edu/regulations/texas/25-Tex-Admin-Code-SS-1-136 "https://www.law.cornell.edu/regulations/texas/25-Tex-Admin-Code-SS-1-136"
[9]: https://www.emergobyul.com/news/10-steps-conducting-use-related-risk-analysis-part-your-human-factors-engineering-process?utm_source=chatgpt.com "10 Steps to Conducting a Use-related Risk Analysis as Part ..."
[10]: https://asq.org/quality-resources/fmea?srsltid=AfmBOoqAZuOIRT8VEXsOfhlGgyJ15ikmCL9wrAVhTKbve4bnzhE93IuP&utm_source=chatgpt.com "What is FMEA? Failure Mode & Effects Analysis"


# 844  _context-commentary_guides-sds.md
METADATA
last updated: 2026-02-17 RT
file_name: _context-commentary_guides-sds.md
category: guides
subcategory: sds
words: 617
tokens: 844


CONTENT

## Context
The SDS subcategory within the Guides collection contains Safety Data Sheets for the key chemicals used in FloodLAMP's LAMP-based COVID-19 testing workflow, along with an original analysis document addressing waste disposal and risk assessment.

The five SDS files cover the chemicals central to FloodLAMP's reagent system:
- **TCEP** (tris(2-carboxyethyl)phosphine hydrochloride) — the reducing agent used in the Inactivation Saline Solution for viral inactivation; classified as a corrosive solid
- **EDTA** (ethylenediaminetetraacetic acid) — the chelating agent also used in the Inactivation Saline Solution; relatively low hazard at working concentrations
- **Clorox Regular Bleach** (sodium hypochlorite 5–10%) — used for decontamination and cleaning at test sites; corrosive with aquatic toxicity concerns
- **Isopropyl Alcohol 70%** — used for surface disinfection; a Class 3 flammable liquid
- **Twist Synthetic SARS-CoV-2 RNA Control** — the non-hazardous synthetic RNA positive control used in test verification

These SDS files were maintained as a convenient reference for FloodLAMP personnel and pilot site operators, providing standardized hazard, handling, PPE, and disposal information for the chemicals they encountered during testing operations.

The sixth file in the subcategory, "Waste Disposal and Risk Assessment," is an original analysis created during archive preparation. It addresses questions that were operationally important during FloodLAMP's active period: whether the used and unused reagents constituted hazardous waste under federal RCRA and state regulations (California, Florida, and Texas), how pilot sites should have disposed of the two primary waste streams (inactivated sample tubes and spent reaction tubes), and what the regulatory landscape looked like for both the chemical and biological components of the waste. The document also reviews a qualitative biological risk assessment that FloodLAMP commissioned in 2022 and the use-FMEA (uFMEA) document (SOP-004-B) that FloodLAMP began developing to obtain the numerical risk quantification the narrative assessment lacked. These disposal and risk questions connect to the manufacturing subcategory (where the reagent formulations are defined) and to the QMS/SOPs subcategory (where the uFMEA and related SOPs reside).


## Commentary
The substantive commentary for this subcategory lives in the "Waste Disposal and Risk Assessment" file, which documents the analysis I wish we had done more rigorously during FloodLAMP's active period. The core issue was straightforward but consequential: we needed to know whether our reagents and testing waste were hazardous, and how pilot sites in three different states should dispose of them. We had a PhD bioscientist research the question multiple times, and the conclusion — that the working-concentration solutions were not hazardous waste — turns out to be substantially correct from a chemical standpoint. But the full picture is more nuanced than we appreciated at the time, particularly around the concentrated 100X Inactivation Solution (which likely qualifies as D002 corrosive hazardous waste due to NaOH concentration) and the biological waste classification question, which is governed by state medical waste regulations rather than RCRA.

The lesson I take from this is about the value of having AI-assisted research tools for these kinds of regulatory and technical questions. All of that earlier research was done pre-AI, without a written record of the reasoning. During archive preparation, I was able to use AI to produce the detailed, chemical-by-chemical analysis with specific regulatory citations that we should have had on file from the start. For any future decentralized testing operation, I would insist on a documented waste determination memo for each site — something that maps each waste stream to the applicable federal and state regulations and reaches an explicit disposal recommendation. AI tools make this kind of thorough, multi-jurisdictional regulatory research dramatically more accessible, even for a small company without in-house regulatory counsel. That is a genuine advancement for the field: the barrier to getting these operational safety and compliance questions properly answered has dropped significantly.


# 4,190  SDS - Clorox Bleach Regular.md
METADATA
last updated: 2025-12-14 RT after BA fixed inconsistencies
file_name: SDS - Clorox Bleach Regular.md
file_date: 2015-06-12
title: Safety Data Sheet - Clorox Bleach Regular
category: guides
subcategory: sds
tags: 
source_file_type: pdf
xfile_type: NA
gfile_url: NA
xfile_github_download_url: NA
pdf_gdrive_url: https://drive.google.com/file/d/1VwgYf7av-AJU_gvS-kpyu0THWaCg2Tvo
pdf_github_url: https://github.com/FocusOnFoundationsNonprofit/floodlamp-archive/blob/main/guides/sds/SDS%20-%20Clorox%20Bleach%20Regular.pdf
conversion_input_file_type: pdf
conversion: ai (claude sonnet 3.5)
license: public domain
tokens: 4190
words: 2755
notes: 
summary_short: The Safety Data Sheet for Clorox® Regular Bleach (sodium hypochlorite 5–10%) outlines hazards, first aid, handling/storage, PPE, and disposal guidance for household disinfecting, sanitizing, and laundry use. It highlights severe skin and eye corrosion risks, toxic gas generation when mixed with acids or ammonia-containing cleaners, and high aquatic toxicity. The sheet also summarizes transport status and key regulatory notes (including EPA pesticide labeling and reportable quantity thresholds).


CONTENT

***INTERNAL TITLE:*** The Clorox Company - Safety Data Sheet

**Issuing Date** January 5, 2015 
**Revision Date** June 12, 2015 
**Revision Number** 1

## 1. Identification of the Substance/Preparation and of the Company/Undertaking
### Product Identifier
**Product Name**: Clorox® Regular-Bleach¹

### Other means of identification
**EPA Registration Number**: 5813-100

### Recommended Use of the Chemical and Restrictions on Use
**Recommended Use**: Household disinfecting, sanitizing, and laundry bleach
**Uses Advised Against**: No information available

### Details of the Supplier of the Safety Data Sheet
**Supplier Address**:
  The Clorox Company
  1221 Broadway
  Oakland, CA 94612

**Phone**: 1-510-271-7000

### Emergency Telephone Number
**Emergency Phone Numbers**:
For Medical Emergencies, call: 1-800-446-1014
For Transportation Emergencies, call Chemtrec: 1-800-424-9300

## 2. Hazards Identification
### Classification
This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200).
|  |  |
|--------|----------------|
| Skin corrosion/irritation | Category 1 |
| Serious eye damage/eye irritation | Category 1 |
||

### GHS Label Elements, Including Precautionary Statements
#### Emergency Overview
**Signal Word**: Danger
**Hazard Statements**:
Causes severe skin burns and eye damage
Causes serious eye damage
**Appearance**: Clear, pale yellow
**Physical State**: Thin liquid
**Odor**: Bleach

### Precautionary Statements - Prevention
Wash face, hands and any exposed skin thoroughly after handling.
Wear protective gloves, protective clothing, face protection, and eye protection such as safety glasses.

### Precautionary Statements - Response
Immediately call a poison center or doctor.
If swallowed: Rinse mouth. Do NOT induce vomiting.
If on skin (or hair): Take off immediately all contaminated clothing. Rinse skin with water.
Wash contaminated clothing before reuse.
If inhaled: Remove person to fresh air and keep comfortable for breathing.
Specific treatment (see supplemental first aid instructions on this label).
If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.

### Precautionary Statements - Storage
Store locked up.

### Precautionary Statements - Disposal
Dispose of contents in accordance with all applicable federal, state, and local regulations.

### Hazards Not Otherwise Classified (HNOC)
Although not expected, heart conditions or chronic respiratory problems such as asthma, chronic bronchitis, or obstructive lung disease may be aggravated by exposure to high concentrations of vapor or mist.

Product contains a strong oxidizer. Always flush drains before and after use.

### Unknown Toxicity
Not applicable.

### Other Information
Very toxic to aquatic life with long lasting effects.

### Interactions with Other Chemicals
Reacts with other household chemicals such as toilet bowl cleaners, rust removers, acids, or products containing ammonia to produce hazardous irritating gases, such as chlorine and other chlorinated compounds.

## 3. Composition/Information on Ingredients
| Chemical Name | CAS-No | Weight % | Trade Secret |
|---------------|--------|----------|--------------|
| Sodium hypochlorite | 7681-52-9 | 5 - 10 | * |
||

*The exact percentage (concentration) of composition has been withheld as a trade secret.

## 4. First Aid Measures
### First Aid Measures
**General Advice**
Call a poison control center or doctor immediately for treatment advice. Show this safety data sheet to the doctor in attendance.

**Eye Contact**
Hold eye open and rinse slowly and gently with water for 15 - 20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice.

**Skin Contact**
Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control center or doctor for treatment advice.

**Inhalation**
Move to fresh air. If breathing is affected, call a doctor.

**Ingestion**
Have person sip a glassful of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center or doctor. Do not give anything by mouth to an unconscious person. Call a poison control center or doctor immediately for treatment advice.

**Protection of First-Aiders**
Avoid contact with skin, eyes, and clothing. Use personal protective equipment as required. Wear personal protective clothing (see section 8).

### Most Important Symptoms and Effects, Both Acute and Delayed
**Most Important Symptoms and Effects**
Burning of eyes and skin.

### Indication of Any Immediate Medical Attention and Special Treatment Needed
**Notes to Physician**
Treat symptomatically. Probable mucosal damage may contraindicate the use of gastric lavage.

## 5. Fire-Fighting Measures
### Suitable Extinguishing Media
Use extinguishing measures that are appropriate to local circumstances and the surrounding environment.

### Unsuitable Extinguishing Media
CAUTION: Use of water spray when fighting fire may be inefficient.

### Specific Hazards Arising from the Chemical
This product causes burns to eyes, skin, and mucous membranes. Thermal decomposition can release sodium chlorate and irritating gases and vapors.

### Explosion Data
**Sensitivity to Mechanical Impact**: None.
**Sensitivity to Static Discharge**: None.

### Protective Equipment and Precautions for Firefighters
As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear.

## 6. Accidental Release Measures
### Personal Precautions, Protective Equipment and Emergency Procedures
**Personal Precautions**
Avoid contact with eyes, skin, and clothing. Ensure adequate ventilation. Use personal protective equipment as required. For spills of multiple products, responders should evaluate the MSDSs of the products for incompatibility with sodium hypochlorite. Breathing protection should be worn in enclosed and/or poorly-ventilated areas until hazard assessment is complete.

**Other Information**
Refer to protective measures listed in Sections 7 and 8.

### Environmental Precautions
**Environmental Precautions**
This product is toxic to fish, aquatic invertebrates, oysters, and shrimp. Do not allow product to enter storm drains, lakes, or streams. See Section 12 for ecological Information.

### Methods and Material for Containment and Cleaning Up
**Methods for Containment**
Prevent further leakage or spillage if safe to do so.

**Methods for Cleaning Up**
Absorb and containerize. Wash residual down to sanitary sewer. Contact the sanitary treatment facility in advance to assure ability to process washed-down material.

## 7. Handling and Storage
### Precautions for Safe Handling
**Handling**
Handle in accordance with good industrial hygiene and safety practice. Avoid contact with skin, eyes, and clothing. Do not eat, drink, or smoke when using this product.

### Conditions for Safe Storage, Including Any Incompatibilities
**Storage**
Store away from children. Reclose cap tightly after each use. Store this product upright in a cool, dry area, away from direct sunlight and heat to avoid deterioration. Do not contaminate food or feed by storage of this product.

**Incompatible Products**
Toilet bowl cleaners, rust removers, acids, and products containing ammonia.

## 8. Exposure Controls/Personal Protection
### Control Parameters
**Exposure Guidelines**
| Chemical Name | ACGIH TLV | OSHA PEL | NIOSH IDLH |
|---------------|-----------|----------|------------|
| Sodium hypochlorite 7681-52-9 | None | None | None |
||

ACGIH TLV: American Conference of Governmental Industrial Hygienists - Threshold Limit Value
OSHA PEL: Occupational Safety and Health Administration - Permissible Exposure Limits
NIOSH IDLH: Immediately Dangerous to Life or Health

### Appropriate Engineering Controls
**Engineering Measures**
Showers
Eyewash stations
Ventilation systems

### Individual Protection Measures, Such as Personal Protective Equipment
**Eye/Face Protection**
If splashes are likely to occur: Wear safety glasses with side shields (or goggles) or face shield.

**Skin and Body Protection**
Wear rubber or neoprene gloves and protective clothing such as long-sleeved shirt.

**Respiratory Protection**
If irritation is experienced, NIOSH/MSHA approved respiratory protection should be worn. Positive-pressure supplied air respirators may be required for high airborne contaminant concentrations. Respiratory protection must be provided in accordance with current local regulations.

**Hygiene Measures**
Handle in accordance with good industrial hygiene and safety practice. Wash hands after direct contact. Do not wear product-contaminated clothing for prolonged periods. Remove and wash contaminated clothing before re-use. Do not eat, drink, or smoke when using this product.

## 9. Physical and Chemical Properties
### Physical and Chemical Properties
**Physical State** Thin liquid
**Appearance** Clear 
**Color** Pale yellow
**Odor** Bleach
**Odor Threshold** No information available

| Property | Value | Remarks/Method |
|----------|-------|----------------|
| Physical State | Thin liquid | None known |
| Appearance | Clear | None known |
| Color | Pale yellow | None known |
| Odor | Bleach | None known |
| Odor Threshold | No information available | None known |
| pH | ~12 | None known |
| Melting/freezing point | No data available | None known |
| Boiling point / boiling range | No data available | None known |
| Flash Point | Not flammable | None known |
| Evaporation rate | No data available | None known |
| Flammability (solid, gas) | No data available | None known |
| Flammability Limits in Air | | |
| Upper flammability limit | No data available | None known |
| Lower flammability limit | No data available | None known |
| Vapor pressure | No data available | None known |
| Vapor density | No data available | None known |
| Specific Gravity | ~1.1 | None known |
| Water Solubility | Soluble | None known |
| Solubility in other solvents | No data available | None known |
| Partition coefficient: n-octanol/water | No data available | None known |
| Autoignition temperature | No data available | None known |
| Decomposition temperature | No data available | None known |
| Kinematic viscosity | No data available | None known |
| Dynamic viscosity | No data available | None known |
| Explosive Properties | Not explosive | |
| Oxidizing Properties | No data available | |
||

### Other Information
| Property | Value |
|----------|-------|
| Softening Point | No data available |  
| VOC Content (%) | No data available |  
| Particle Size | No data available | 
| Particle Size Distribution | No data available | 
||

## 10. Stability and Reactivity
### Reactivity
Reacts with other household chemicals such as toilet bowl cleaners, rust removers, acids, or products containing ammonia to produce hazardous irritating gases, such as chlorine and other chlorinated compounds.

### Chemical Stability
Stable under recommended storage conditions.

### Possibility of Hazardous Reactions
None under normal processing.

### Conditions to Avoid
None known based on information supplied.

### Incompatible Materials
Toilet bowl cleaners, rust removers, acids, and products containing ammonia.

### Hazardous Decomposition Products
None known based on information supplied.

## 11. Toxicological Information
### Information on Likely Routes of Exposure
#### Product Information
**Inhalation**
Exposure to vapor or mist may irritate respiratory tract and cause coughing. Inhalation of high concentrations may cause pulmonary edema.

**Eye Contact**
Corrosive. May cause severe damage to eyes.

**Skin Contact**
May cause severe irritation to skin. Prolonged contact may cause burns to skin.

**Ingestion**
Ingestion may cause burns to gastrointestinal tract and respiratory tract, nausea, vomiting, and diarrhea.

#### Component Information

| Chemical Name | LD50 Oral | LD50 Dermal | LC50 Inhalation |
|---------------|-----------|-------------|-----------------|
| Sodium hypochlorite 7681-52-9 | 8200 mg/kg (Rat) | >10000 mg/kg (Rabbit) | - |
||

### Information on Toxicological Effects
**Symptoms**
May cause redness and tearing of the eyes. May cause burns to eyes. May cause redness or burns to skin. Inhalation may cause coughing.

### Delayed and Immediate Effects as well as Chronic Effects from Short and Long-Term Exposure
**Sensitization**
No information available.

**Mutagenic Effects**
No information available.

**Carcinogenicity**
The table below indicates whether each agency has listed any ingredient as a carcinogen.
| Chemical Name | ACGIH | IARC | NTP | OSHA |
|---------------|-------|------|-----|------|
| Sodium hypochlorite 7681-52-9 | - | Group 3 | - | - |
||

IARC (International Agency for Research on Cancer)
Group 3 - Not Classifiable as Carcinogenicity in Humans

**Reproductive Toxicity**
No information available.

**STOT - Single Exposure**
No information available.

**STOT - Repeated Exposure**
No information available.

**Chronic Toxicity**
Carcinogenic potential is unknown.

**Target Organ Effects**
Respiratory system, eyes, skin, gastrointestinal tract (GI).

**Aspiration Hazard**
No information available.

### Numerical Measures of Toxicity - Product Information
The following values are calculated based on chapter 3.1 of the GHS document:
**ATEmix (oral)** 
54 g/kg
**ATEmix (inhalation-dust/mist)**
58 mg/L

## 12. Ecological Information
### Ecotoxicity
Very toxic to aquatic life with long lasting effects.

This product is toxic to fish, aquatic invertebrates, oysters, and shrimp. Do not allow product to enter storm drains, lakes, or streams.

### Persistence and Degradability
No information available.

### Bioaccumulation
No information available.

### Other Adverse Effects
No information available.

## 13. Disposal Considerations
### Disposal Methods
Dispose of in accordance with all applicable federal, state, and local regulations. Do not contaminate food or feed by disposal of this product.

### Contaminated Packaging
Do not reuse empty containers. Dispose of in accordance with all applicable federal, state, and local regulations.

## 14. Transport Information
### DOT
Not restricted.

### TDG
Not restricted for road or rail.

### ICAO
Not restricted, as per Special Provision A197, Environmentally Hazardous Substance exception.

### IATA
Not restricted, as per Special Provision A197, Environmentally Hazardous Substance exception.

### IMDG/IMO
Not restricted, as per IMDG Code 2.10.2.7, Marine Pollutant exception.

## 15. Regulatory Information
### Chemical Inventories
**TSCA**
All components of this product are either on the TSCA 8(b) Inventory or otherwise exempt from listing.

**DSL/NDSL**
All components are on the DSL or NDSL.

**TSCA** - United States Toxic Substances Control Act Section 8(b) Inventory
**DSL/NDSL** - Canadian Domestic Substances List/Non-Domestic Substances List

### U.S. Federal Regulations
**SARA 313**
Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). This product does not contain any chemicals which are subject to the reporting requirements of the Act and Title 40 of the Code of Federal Regulations, Part 372.

**SARA 311/312 Hazard Categories**
- Acute Health Hazard: Yes
- Chronic Health Hazard: No
- Fire Hazard: No
- Sudden Release of Pressure Hazard: No
- Reactive Hazard: No

**Clean Water Act**
This product contains the following substances which are regulated pollutants pursuant to the Clean Water Act (40 CFR 122.21 and 40 CFR 122.42)
| Chemical Name | CWA - Reportable Quantities | CWA - Toxic Pollutants | CWA - Priority Pollutants | CWA - Hazardous Substances |
|---------------|------------------------------|------------------------|---------------------------|----------------------------|
| Sodium hypochlorite 7681-52-9 | 100 lb | - | - | X |
||

**CERCLA**
This material, as supplied, contains one or more substances regulated as a hazardous substance under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40 CFR 302)
| Chemical Name | Hazardous Substances RQs | Extremely Hazardous Substances RQs | RQ |
|---------------|---------------------------|------------------------------------|----|
| Sodium hypochlorite 7681-52-9 | 100 lb | - | RQ 100 lb final RQ RQ 45.4 kg final RQ |
||

**EPA Statement**
This chemical is a pesticide product registered by the Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets and for workplace labels of non-pesticide chemicals. Following is the hazard information as required on the pesticide label:

**DANGER: CORROSIVE.** Causes irreversible eye damage and skin burns. Harmful if swallowed. Do not get in eyes, on skin, or on clothing. Wear protective eyewear and rubber gloves when handling this product. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum, using tobacco, or using the restroom. Avoid breathing vapors and use only in a well-ventilated area.

### US State Regulations
**California Proposition 65**
This product does not contain any Proposition 65 chemicals.

**U.S. State Right-to-Know Regulations**
| Chemical Name | New Jersey | Massachusetts | Pennsylvania | Rhode Island | Illinois |
|---------------|------------|---------------|--------------|--------------|----------|
| Sodium hypochlorite 7681-52-9 | X | X | X | X | - |
| Sodium chlorate 7775-09-9 | X | X | X | - | - |
||

### International Regulations
**Canada**
WHMIS Hazard Class
E - Corrosive material

## 16. Other Information
### NFPA   
Health Hazard: 3
Flammability: 0
Instability: 0
Physical and Chemical Hazards: -

### HMIS   
Health Hazard: 3
Flammability: 0
Physical Hazard: 0
Personal Protection: B

**Prepared By**
Product Stewardship  
23 British American Blvd.  
Latham, NY 12110  
1-800-572-6501

**Revision Date**
June 12, 2015

**Revision Note**
Revision Section 14.

**Reference**
1096036/164964.159  

### General Disclaimer
The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal, and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text.

End of Safety Data Sheet


# 3,537  SDS - EDTA.md
METADATA
last updated: 2025-12-14 RT after BA fixed inconsistencies
file_name: SDS - EDTA.md
file_date: 2018-01-18
title: Safety Data Sheet - EDTA
category: guides
subcategory: sds
tags: 
source_file_type: pdf
xfile_type: NA
gfile_url: NA
xfile_github_download_url: NA
pdf_gdrive_url: https://drive.google.com/file/d/1sUCW4idcd041WWuOUOgRoQvt1X5mqoNY
pdf_github_url: https://github.com/FocusOnFoundationsNonprofit/floodlamp-archive/blob/main/guides/sds/SDS%20-%20EDTA.pdf
conversion_input_file_type: pdf
conversion: ai (claude sonnet 3.5)
license: public domain
tokens: 3537
words: 2062
notes: 
summary_short: The Safety Data Sheet for EDTA (ethylenediaminetetraacetic acid, CAS 60-00-4) summarizes hazards, safe handling/storage, exposure controls, and emergency measures for laboratory use. It identifies inhalation (dust/mist) and eye irritation risks with potential respiratory effects from repeated exposure, and provides spill cleanup, fire response, and disposal guidance. The sheet also notes aquatic toxicity, transport as not regulated, and key regulatory/inventory listings and reportable quantity thresholds.


CONTENT

***INTERNAL TITLE:*** ThermoFisher Scientific - Safety Data Sheet

**Creation Date** 02-Jan-2015 
**Revision Date** 18-Jan-2018 
**Revision Number** 6

## 1. Identification
**Product Name:** Ethylenediamine Tetraacetic Acid

**Cat No.:** BP118-500; E478-1; E478-10; E478-500; NC1065691; XXBP118-10KG; NC1163901; XXE478-12KG; NC1253743

**CAS-No:** 60-00-4

**Synonyms:** 
- 3,6-Diazaoctanedioic acid, 3,6-bis(carboxymethy)
- Acetic acid, (Ethylenedinitrilo)tetraacetic acid
- EDTA
- Edetic acid
- Diaminoethanetetraacetic acid

**Recommended Use:** Laboratory chemicals

**Uses advised against:** Not for food, drug, pesticide or biocidal product use

**Details of the supplier of the safety data sheet:**

**Company:**
Fisher Scientific
One Reagent Lane
Fair Lawn, NJ 07410
Tel: (201) 796-7100

**Emergency Telephone Number:**
CHEMTRECÒ, Inside the USA: 800-424-9300
CHEMTRECÒ, Outside the USA: 001-703-527-3887

## 2. Hazard(s) identification
### Classification
This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200)
|  |  |
|--------|----------|
| Acute Inhalation Toxicity - Dusts and Mists | Category 4 |
| Serious Eye Damage/Eye Irritation | Category 2 |
| Specific target organ toxicity - (repeated exposure) | Category 2 |
| Target Organs - Respiratory system. | - |
||

### Label Elements
**Signal Word:** Warning

**Hazard Statements:**
- Causes serious eye irritation
- Harmful if inhaled
- May cause damage to organs through prolonged or repeated exposure

**Precautionary Statements:**
*Prevention:*
- Use only outdoors or in a well-ventilated area
- Wash face, hands and any exposed skin thoroughly after handling
- Wear eye/face protection
- Do not breathe dust/fume/gas/mist/vapors/spray

*Response:*
- Get medical attention/advice if you feel unwell

*Inhalation:*
- IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing
- Call a POISON CENTER or doctor/physician if you feel unwell

*Eyes:*
- IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing
- If eye irritation persists: Get medical advice/attention

*Disposal:*
- Dispose of contents/container to an approved waste disposal plant

**Hazards not otherwise classified (HNOC):** None identified

## 3. Composition/Information on Ingredients
| Component | CAS-No | Weight % |
|-----------|--------|----------|
| Ethylenediamine tetraacetic acid (EDTA) | 60-00-4 | > 99 |
||

## 4. First-aid measures
**General Advice:** If symptoms persist, call a physician.

**Eye Contact:** Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Obtain medical attention if irritation persists.

**Skin Contact:** Wash off immediately with plenty of water for at least 15 minutes. If skin irritation persists, call a physician.

**Inhalation:** Move to fresh air. If not breathing, give artificial respiration. Get medical attention if symptoms occur.

**Ingestion:** Clean mouth with water and drink afterwards plenty of water. Get medical attention if symptoms occur.

**Most important symptoms and effects:** None reasonably foreseeable.

**Notes to Physician:** Treat symptomatically

## 5. Fire-fighting measures
**Suitable Extinguishing Media:** Use water spray, alcohol-resistant foam, dry chemical or carbon dioxide.

**Unsuitable Extinguishing Media:** No information available

**Flash Point:** Not applicable

**Method:** No information available

**Autoignition Temperature:** Not applicable 200 °C / 392 °F

**Explosion Limits:**
- Upper: No data available
- Lower: No data available
- Sensitivity to Mechanical Impact: No information available
- Sensitivity to Static Discharge: No information available

**Specific Hazards Arising from the Chemical:** Thermal decomposition can lead to release of irritating gases and vapors. Keep product and empty container away from heat and sources of ignition.

**Hazardous Combustion Products:** Nitrogen oxides (NOx), Carbon monoxide (CO), Carbon dioxide (CO2)

**Protective Equipment and Precautions for Firefighters:** As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear.

**NFPA:**
- Health: 2
- Flammability: 1
- Instability: 0
- Physical hazards: N/A

## 6. Accidental release measures
**Personal Precautions:** Use personal protective equipment. Ensure adequate ventilation. Avoid dust formation.

**Environmental Precautions:** Do not flush into surface water or sanitary sewer system.

**Methods for Containment and Clean Up:** Sweep up or vacuum up spillage and collect in suitable container for disposal. Keep in suitable, closed containers for disposal.

## 7. Handling and storage
**Handling:** Wear personal protective equipment. Ensure adequate ventilation. Avoid dust formation. Do not get in eyes, on skin, or on clothing. Avoid ingestion and inhalation.

**Storage:** Keep in a dry, cool and well-ventilated place. Keep container tightly closed.

## 8. Exposure controls / personal protection
**Exposure Guidelines:** This product does not contain any hazardous materials with occupational exposure limits established by the region-specific regulatory bodies.

**Engineering Measures:** Ensure adequate ventilation, especially in confined areas. Ensure that eyewash stations and safety showers are close to the workstation location.

**Personal Protective Equipment:**
*Eye/face Protection:* Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166.

*Skin and body protection:* Long sleeved clothing.

*Respiratory Protection:* Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149. Use a NIOSH/MSHA or European Standard EN 149 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced.

*Hygiene Measures:* Handle in accordance with good industrial hygiene and safety practice.

## 9. Physical and chemical properties
|  |  |
|----------|-------|
| Physical State | Powder Solid |
| Appearance | White |
| Odor | Odorless |
| Odor Threshold | No information available |
| pH | 2.5 10 g/L (23°C) |
| Melting Point/Range | 220 °C / 428 °F |
| Boiling Point/Range | No information available |
| Flash Point | Not applicable |
| Evaporation Rate | Not applicable |
| Flammability (solid,gas) | No information available |
| Flammability or explosive limits | Upper: No data available<br>Lower: No data available |
| Vapor Pressure | 0.013 hPa @ 20 °C |
| Vapor Density | Not applicable |
| Specific Gravity | 0.86 @ 20°C |
| Solubility | Slightly soluble in water |
| Partition coefficient; n-octanol/water | No data available |
| Autoignition Temperature | Not applicable 200 °C / 392 °F |
| Decomposition Temperature | > 150°C |
| Viscosity | Not applicable |
| Molecular Formula | C10 H16 N2 O8 |
| Molecular Weight | 292.23 |
||

## 10. Stability and reactivity
**Reactive Hazard:** None known, based on information available

**Stability:** Stable under normal conditions.

**Conditions to Avoid:** Avoid dust formation. Incompatible products. Excess heat.

**Incompatible Materials:** Strong oxidizing agents, Strong bases, Metals, copper

**Hazardous Decomposition Products:** Nitrogen oxides (NOx), Carbon monoxide (CO), Carbon dioxide (CO2)

**Hazardous Polymerization:** Hazardous polymerization does not occur.

**Hazardous Reactions:** None under normal processing.

## 11. Toxicological information
### Acute Toxicity
**Product Information**
**Component Information**
| Component | LD50 Oral | LD50 Dermal | LC50 Inhalation |
|-----------|-----------|-------------|------------------|
| Ethylenediamine tetraacetic acid (EDTA) | 4500 mg/kg ( Rat )<br>>2000 mg/kg ( Rat ) | Not listed | 1 mg/l (rat) |
||

**Toxicologically Synergistic Products:** No information available

### Delayed and immediate effects as well as chronic effects from short and long-term exposure
**Irritation:** Irritating to eyes

**Sensitization:** No information available

**Carcinogenicity:** The table below indicates whether each agency has listed any ingredient as a carcinogen.
| Component | CAS-No | IARC | NTP | ACGIH | OSHA | Mexico |
|-----------|--------|------|-----|-------|------|--------|
| Ethylenediamine tetraacetic acid (EDTA) | 60-00-4 | Not listed | Not listed | Not listed | Not listed | Not listed |
||

**Mutagenic Effects:** No information available

**Reproductive Effects:** No information available.

**Developmental Effects:** No information available.

**Teratogenicity:** No information available.

**STOT - single exposure:** None known

**STOT - repeated exposure:** Respiratory system

**Aspiration hazard:** No information available

**Symptoms / effects, both acute and delayed:** No information available

**Endocrine Disruptor Information:** No information available

**Other Adverse Effects:** The toxicological properties have not been fully investigated.

## 12. Ecological information
### Ecotoxicity
Contains a substance which is: The product contains following substances which are hazardous for the environment. Toxic to aquatic organisms.
| Component | Freshwater Algae | Freshwater Fish | Microtox | Water Flea |
|-----------|------------------|-----------------|----------|------------|
| Ethylenediamine tetraacetic acid (EDTA) | EC50: = 1.01 mg/L, 72h (Desmodesmus subspicatus) | LC50: 44.2 - 76.5 mg/L, 96h static (Pimephales promelas)<br>LC50: 34 - 62 mg/L, 96h static (Lepomis macrochirus) | Not listed | EC50: = 113 mg/L, 48h Static (Daphnia magna) |
||

**Persistence and Degradability:** Soluble in water Persistence is unlikely based on information available.

**Bioaccumulation/ Accumulation:** No information available.

**Mobility:** Will likely be mobile in the environment due to its water solubility.

## 13. Disposal considerations
**Waste Disposal Methods:** Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. Chemical waste generators must also consult local, regional, and national hazardous waste regulations to ensure complete and accurate classification.

## 14. Transport information
**DOT:** Not regulated

**TDG:** Not regulated

**IATA:** Not regulated

**IMDG/IMO:** Not regulated

## 15. Regulatory information
**International Inventories:**
| Component | TSCA | DSL | NDSL | EINECS | ELINCS | NLP | PICCS | ENCS | AICS | IECSC | KECL |
|-----------|------|-----|------|--------|--------|-----|-------|------|------|-------|------|
| Ethylenediamine tetraacetic acid (EDTA) | X | X | - | 200-449-4 | - |  | X | X | X | X | X |
||

**Legend:**
X - Listed
E - Indicates a substance that is the subject of a Section 5(e) Consent order under TSCA.
F - Indicates a substance that is the subject of a Section 5(f) Rule under TSCA.
N - Indicates a polymeric substance containing no free-radical initiator in its inventory name but is considered to cover the designated polymer made with any free-radical initiator regardless of the amount used.
P - Indicates a commenced PMN substance
R - Indicates a substance that is the subject of a Section 6 risk management rule under TSCA.
S - Indicates a substance that is identified in a proposed or final Significant New Use Rule
T - Indicates a substance that is the subject of a Section 4 test rule under TSCA.
XU - Indicates a substance exempt from reporting under the Inventory Update Rule, i.e. Partial Updating of the TSCA Inventory Data Base Production and Site Reports (40 CFR 710(B).
Y1 - Indicates an exempt polymer that has a number-average molecular weight of 1,000 or greater.
Y2 - Indicates an exempt polymer that is a polyester and is made only from reactants included in a specified list of low concern reactants that comprises one of the eligibility criteria for the exemption rule.

### U.S. Federal Regulations
**TSCA 12(b):** Not applicable

**SARA 313:** Not applicable

**SARA 311/312 Hazard Categories:** See section 2 for more information

**CWA (Clean Water Act):**
| Component | CWA - Hazardous Substances | CWA - Reportable Quantities | CWA - Toxic Pollutants | CWA - Priority Pollutants |
|-----------|----------------------------|-----------------------------|-----------------------|---------------------------|
| Ethylenediamine tetraacetic acid (EDTA) | X | 5000 lb | - | - |
||

**Clean Air Act:** Not applicable

**OSHA Occupational Safety and Health Administration:** Not applicable

**CERCLA:**
| Component | Hazardous Substances RQs | CERCLA EHS RQs |
|-----------|--------------------------|-----------------|
| Ethylenediamine tetraacetic acid (EDTA) | 5000 lb | - |
||

**California Proposition 65:** This product does not contain any Proposition 65 chemicals

**U.S. State Right-to-Know Regulations:**
| Component | Massachusetts | New Jersey | Pennsylvania | Illinois | Rhode Island |
|-----------|---------------|------------|--------------|----------|---------------|
| Ethylenediamine tetraacetic acid (EDTA) | X | X | X | - | - |
||

**U.S. Department of Transportation:**
- Reportable Quantity (RQ): N
- DOT Marine Pollutant: N
- DOT Severe Marine Pollutant: N

**U.S. Department of Homeland Security:** This product does not contain any DHS chemicals.

### Other International Regulations
**Mexico - Grade:** No information available

## 16. Other information
**Prepared By:** 
Regulatory Affairs
Thermo Fisher Scientific
Email: EMSDS.RA@thermofisher.com

**Creation Date:** 02-Jan-2015
**Revision Date:** 18-Jan-2018
**Print Date:** 18-Jan-2018
**Revision Summary:** This document has been updated to comply with the US OSHA HazCom 2012 Standard replacing the current legislation under 29 CFR 1910.1200 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

**Disclaimer:**
The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information
relates only to the specific material designated and may not be valid for such material used in combination with any other
materials or in any process, unless specified in the text

End of SDS


# 4,174  SDS - Isopropyl Alcohol 70 percent.md
METADATA
last updated: 2025-12-14 RT after BA fixed inconsistencies
file_name: SDS - Isopropyl Alcohol 70 percent.md
file_date: 2015-06-15
title: Safety Data Sheet - Isopropyl Alcohol 70 percent
category: guides
subcategory: sds
tags: 
source_file_type: pdf
xfile_type: NA
gfile_url: NA
xfile_github_download_url: NA
pdf_gdrive_url: https://drive.google.com/file/d/1t3nmM5TzDTYJGdCxjStDCkqXa49rh947
pdf_github_url: https://github.com/FocusOnFoundationsNonprofit/floodlamp-archive/blob/main/guides/sds/SDS%20-%20Isopropyl%20Alcohol%2070%20percent.pdf
conversion_input_file_type: pdf
conversion: ai (claude sonnet 3.5)
license: public domain
tokens: 4174
words: 2300
notes: 
summary_short: The Safety Data Sheet for 70% isopropyl alcohol (70% isopropanol, 30% water) summarizes composition, hazards, first aid, handling/storage, exposure controls, and disposal guidance for isopropyl rubbing alcohol. It emphasizes flammability (Class 3 flammable liquid) and irritation/toxic effects from skin, eye, inhalation, or ingestion exposure, including CNS effects at high concentrations. The sheet provides spill and fire response procedures, lists key exposure limits, and notes transport identification as UN 1219 (Isopropanol, solution, PG II).


CONTENT

***INTERNAL TITLE:*** Isopropyl Alcohol, 70% Safety Data Sheet

## Section 1: Chemical Product and Company Identification
**Product Name:** Isopropyl Alcohol, 70%  
**Catalog Codes:** SLI1669  
**CAS#:** Mixture  
**RTECS:** Not applicable  
**TSCA:** TSCA 8(b) inventory: Isopropyl alcohol; Water  
**CI#:** Not available  
**Synonym:** 2-Propanol, 70%; Isoprpanol, 70%; Isopropyl Rubbing Alcohol  
**Chemical Name:** Not applicable  
**Chemical Formula:** Not applicable  

**Contact Information:**  
Breen Laboratories  
841 Sandhill Avenue  
Carson, CA 90746  
Ph: 310-366-7121  
Fx: 310-366-7123  
E-mail: Breenlabs@gmail.com  

**CHEMTREC (24HR Emergency Telephone):** 1-800-424-9300  
**International CHEMTREC:** 1-703-527-3887  
**For non-emergency assistance:** 1-281-441-4400  

## Section 2: Composition and Information on Ingredients
**Composition**
| Name | CAS # | % by Weight |
|------|-------|-------------|
| Isopropyl alcohol | 67-63-0 | 70 |
| Water | 7732-18-5 | 30 |
||

**Toxicological Data on Ingredients:**  
Isopropyl alcohol:  
- ORAL (LD50): Acute: 5045 mg/kg [Rat]. 3600 mg/kg [Mouse]. 6410 mg/kg [Rabbit].  
- DERMAL (LD50): Acute: 12800 mg/kg [Rabbit].

## Section 3: Hazards Identification
**Potential Acute Health Effects:**  
Hazardous in case of skin contact (irritant), of eye contact (irritant), of ingestion. Slightly hazardous in case of skin contact (sensitizer, permeator). Non-corrosive for skin. Non-corrosive to the eyes. Non-corrosive for lungs.

**Potential Chronic Health Effects:**  
CARCINOGENIC EFFECTS: Classified A4 (Not classifiable for human or animal.) by ACGIH, 3 (Not classifiable for human.) by IARC [Isopropyl alcohol]. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Classified Reproductive system/toxin/female, Development toxin [POSSIBLE] [Isopropyl alcohol]. The substance may be toxic to kidneys, liver, skin, central nervous system (CNS). Repeated or prolonged exposure to the substance can produce target organs damage.

## Section 4: First Aid Measures
**Eye Contact:**  
Check for and remove any contact lenses. In case of contact, immediately flush eyes with plenty of water for at least 15 minutes. Cold water may be used. Get medical attention.

**Skin Contact:**  
In case of contact, immediately flush skin with plenty of water. Cover the irritated skin with an emollient. Remove contaminated clothing and shoes. Cold water may be used. Wash clothing before reuse. Thoroughly clean shoes before reuse. Get medical attention.

**Serious Skin Contact:**  
Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek medical attention.

**Inhalation:**  
If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical attention if symptoms appear.

**Serious Inhalation:**  
Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek medical attention.

**Ingestion:**  
Do NOT induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious person. Loosen tight clothing such as a collar, tie, belt or waistband. Get medical attention if symptoms appear.

**Serious Ingestion:** Not available.

## Section 5: Fire and Explosion Data
**Flammability of the Product:** Flammable.

**Auto-Ignition Temperature:** The lowest known value is 399°C (750.2°F) (Isopropyl alcohol).

**Flash Points:** CLOSED CUP: 18.3°C (64.9°F) - 24 deg. C (75 deg. F)

**Flammable Limits:** The greatest known range is LOWER: 2% UPPER: 12.7% (Isopropyl alcohol)

**Products of Combustion:** These products are carbon oxides (CO, CO2).

**Fire Hazards in Presence of Various Substances:**  
Highly flammable in presence of open flames and sparks, of heat. Flammable in presence of oxidizing materials. Non-flammable in presence of shocks.

**Explosion Hazards in Presence of Various Substances:**  
Slightly explosive in presence of open flames and sparks, of heat. Non-explosive in presence of shocks.

**Fire Fighting Media and Instructions:**  
Flammable liquid, soluble or dispersed in water. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog.

**Special Remarks on Fire Hazards:**  
Vapor may travel considerable distance to source of ignition and flash back. CAUTION: MAY BURN WITH NEAR INVISIBLE FLAME. Hydrogen peroxide sharply reduces the autoignition temperature of Isopropyl alcohol. After a delay, Isopropyl alcohol ignites on contact with dioxgenyl tetrafluorborate, chromium trioxide, and potassium tert-butoxide. When heated to decomposition it emits acrid smoke and fumes. (Isopropyl alcohol)

**Special Remarks on Explosion Hazards:**  
Secondary alcohols are readily autooxidized in contact with oxygen or air, forming ketones and hydrogen peroxide. It can become potentially explosive. It reacts with oxygen to form dangerously unstable peroxides which can concentrate and explode during distillation or evaporation. The presence of 2-butanone increases the reaction rate for peroxide formation. Explosive in the form of vapor when exposed to heat or flame. May form explosive mixtures with air. Isopropyl alcohol + phosgene forms isopropyl chloroformate and hydrogen chloride. In the presence of iron salts, thermal decompositon can occur, which in some cases can become explosive. A homogeneous mixture of concentrated peroxides + isopropyl alcohol are capable of detonation by shock or heat. Barium perchlorate + isopropyl alcohol gives the highly explosive alkyl perchlorates. It forms explosive mixtures with trinitormethane and hydrogen peroxide. It produces a violent explosive reaction when heated with aluminum isopropoxide + crotonaldehyde. Mixtures of isopropyl alcohol + nitroform are explosive.

## Section 6: Accidental Release Measures
**Small Spill:**  
Dilute with water and mop up, or absorb with an inert dry material and place in an appropriate waste disposal container.

**Large Spill:**  
Flammable liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth, sand or other non-combustible material. Do not touch spilled material. Prevent entry into sewers, basements or confined areas; dike if needed. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.

## Section 7: Handling and Storage
**Precautions:**  
Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/vapor/spray. Wear suitable protective clothing. In case of insufficient ventilation, wear suitable respiratory equipment. If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes. Keep away from incompatibles such as oxidizing agents, acids.

**Storage:**  
Store in a segregated and approved area. Keep container in a cool, well-ventilated area. Keep container tightly closed and sealed until ready for use. Avoid all possible sources of ignition (spark or flame).

## Section 8: Exposure Controls/Personal Protection
**Engineering Controls:**  
Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location.

**Personal Protection:**  
Safety glasses. Lab coat. Dust respirator. Be sure to use an approved/certified respirator or equivalent. Gloves (impervious).

**Personal Protection in Case of a Large Spill:**  
Splash goggles. Full suit. Dust respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.

**Exposure Limits:**  
Isopropyl alcohol  
TWA: 983 STEL: 1230 (mg/m3) [Australia]  
TWA: 200 STEL: 400 (ppm) from ACGIH (TLV) [United States] [1999]  
TWA: 980 STEL: 1225 (mg/m3) from NIOSH  
TWA: 400 STEL: 500 (ppm) from NIOSH  
TWA: 400 STEL: 500 (ppm) [United Kingdom (UK)]  
TWA: 999 STEL: 1259 (mg/m3) [United Kingdom (UK)]  
TWA: 400 STEL: 500 (ppm) from OSHA (PEL) [United States]  
TWA: 980 STEL: 1225 (mg/m3) from OSHA (PEL) [United States]  
Consult local authorities for acceptable exposure limits.

## Section 9: Physical and Chemical Properties
- **Physical state and appearance:** Liquid.
- **Odor:** Alcohol like.
- **Taste:** Not available.
- **Molecular Weight:** Not applicable.
- **Color:** Clear Colorless.
- **pH (1% soln/water):** Neutral.
- **Boiling Point:** The lowest known value is 82.5°C (180.5°F) (Isopropyl alcohol). Weighted average: 87.75°C (189.9°F)
- **Melting Point:** May start to solidify at -88.5°C (-127.3°F) based on data for: Isopropyl alcohol.
- **Critical Temperature:** The lowest known value is 235°C (455°F) (Isopropyl alcohol).
- **Specific Gravity:** Weighted average: 0.84 (Water = 1)
- **Vapor Pressure:** The highest known value is 4.4 kPa (@ 20°C) (Isopropyl alcohol). Weighted average: 3.77 kPa (@ 20°C)
- **Vapor Density:** The highest known value is 2.07 (Air = 1) (Isopropyl alcohol). Weighted average: 1.63 (Air = 1)
- **Volatility:** Not available.
- **Odor Threshold:** The highest known value is 22 ppm (Isopropyl alcohol)
- **Water/Oil Dist. Coeff.:** The product is equally soluble in oil and water.
- **Ionicity (in Water):** Not available.
- **Dispersion Properties:** See solubility in water, methanol, diethyl ether, n-octanol, acetone.
- **Solubility:** Easily soluble in cold water, hot water, methanol, diethyl ether, n-octanol, acetone.

## Section 10: Stability and Reactivity Data
- **Stability:** The product is stable.
- **Instability Temperature:** Not available.
- **Conditions of Instability:** Heat, flame, ignition sources, incompatible materials
- **Incompatibility with various substances:** Reactive with oxidizing agents, acids, alkalis.
- **Corrosivity:** Non-corrosive in presence of glass.
- **Special Remarks on Reactivity:** Reacts violently with hydrogen + palladium combination, nitroform, oleum, COCl2, aluminum triisopropoxide, oxidants. Incompatible with acetaldehyde, chlorine, ethylene oxide, isocyanates, acids, alkaline earth, alkali metals, caustics, amines, crotonaldehyde, phosgene, ammonia. Isopropyl alcohol reacts with metallic aluminum at high temperatures. Isopropyl alcohol attacks some plastics, rubber, and coatings. Vigorous reaction with sodium dichromate + sulfuric acid.
- **Special Remarks on Corrosivity:** Not available.
- **Polymerization:** Will not occur.

## Section 11: Toxicological Information
- **Routes of Entry:** Absorbed through skin. Eye contact. Inhalation.
- **Toxicity to Animals:** 
  - Acute oral toxicity (LD50): 5143 mg/kg (Mouse) (Calculated value for the mixture).
  - Acute dermal toxicity (LD50): 18286 mg/kg (Rabbit) (Calculated value for the mixture).
- **Chronic Effects on Humans:** 
  - CARCINOGENIC EFFECTS: Classified A4 (Not classifiable for human or animal.) by ACGIH, 3 (Not classifiable for human.) by IARC [Isopropyl alcohol].
  - DEVELOPMENTAL TOXICITY: Classified Reproductive system/toxin/female, Development toxin [POSSIBLE] [Isopropyl alcohol].
  - May cause damage to the following organs: kidneys, liver, skin, central nervous system (CNS).
- **Other Toxic Effects on Humans:** 
  - Hazardous in case of skin contact (irritant), of ingestion, of inhalation.
  - Slightly hazardous in case of skin contact (sensitizer, permeator).
- **Special Remarks on Toxicity to Animals:** Not available.
- **Special Remarks on Chronic Effects on Humans:** May cause adverse reproductive/teratogenic effects (fertility, fetoxicity, developmental abnormalities) based on animal studies. Detected in maternal milk in human.
- **Special Remarks on other Toxic Effects on Humans:** 
  - Acute Potential Health Effects:
    - Skin: May cause mild skin irritation, and sensitization.
    - Eyes: Can cause eye irritation.
    - Inhalation: Breathing in small amounts of this material during normal handling is not likely to cause harmful effects. However, breathing large amounts may be harmful and may affect the respiratory system and mucous membranes (irritation), behavior and brain (Central nervous system depression - headache, dizziness, drowsiness, stupor, incoordination, unconsciousness, coma and possible death), peripheral nerve and sensation, blood, urinary system, and liver.
    - Ingestion: Swallowing small amounts during normal handling is not likely to cause harmful effects. Swallowing large amounts may be harmful. Swallowing large amounts may cause gastrointestinal tract irritation with nausea, vomiting and diarrhea, abdominal pain. It also may affect the urinary system, cardiovascular system, sense organs, behavior or central nervous system (somnolence, generally depressed activity, irritability, headache, dizziness, drowsiness), liver, and respiratory system (breathing difficulty).

## Section 12: Ecological Information
- **Ecotoxicity:** Not available.
- **BOD5 and COD:** Not available.
- **Products of Biodegradation:** Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.
- **Toxicity of the Products of Biodegradation:** The product itself and its products of degradation are not toxic.
- **Special Remarks on the Products of Biodegradation:** Not available.

## Section 13: Disposal Considerations
**Waste Disposal:** Waste must be disposed of in accordance with federal, state and local environmental control regulations.

## Section 14: Transport Information
- **DOT Classification:** CLASS 3: Flammable liquid.
- **Identification:** Isopropanol, solution (Isopropyl alcohol) UNNA: 1219 PG: II
- **Special Provisions for Transport:** Not available.

## Section 15: Other Regulatory Information
**Federal and State Regulations:**  
Connecticut hazardous material survey.: Isopropyl alcohol  
Illinois toxic substances disclosure to employee act: Isopropyl alcohol  
Rhode Island RTK hazardous substances: Isopropyl alcohol  
Pennsylvania RTK: Isopropyl alcohol  
Florida: Isopropyl alcohol  
Minnesota: Isopropyl alcohol  
Massachusetts RTK: Isopropyl alcohol  
New Jersey: Isopropyl alcohol  
New Jersey spill list: Isopropyl alcohol  
TSCA 8(b) inventory: Isopropyl alcohol; Water  
TSCA 4(a) final testing order: Isopropyl alcohol  
TSCA 8(a) IUR: Isopropyl alcohol  
TSCA 8(d) H and S data reporting: Isopropyl alcohol: Effective date: 12/15/86 Sunset Date: 12/15/96  
TSCA 12(b) one time export: Isopropyl alcohol  
SARA 313 toxic chemical notification and release reporting: Isopropyl alcohol 70%  

**Other Regulations:**  
OSHA: Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200).  

**Other Classifications:**

**WHMIS (Canada):**  
CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F).  
CLASS D-2B: Material causing other toxic effects (TOXIC).  

**DSCL (EEC):**  
R11- Highly flammable.  
R36- Irritating to eyes.  
S2- Keep out of the reach of children.  
S46- If swallowed, seek medical advice immediately and show this container or label.  

**HMIS (U.S.A.):**  
Health Hazard: 2  
Fire Hazard: 3  
Reactivity: 0  
Personal Protection: E  

**National Fire Protection Association (U.S.A.):**  
Health: 1  
Flammability: 3  
Reactivity: 0  
Specific hazard:  

**Protective Equipment:**  
Gloves (impervious). Lab coat. Dust respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Safety glasses.  

## Section 16: Other Information
- **References:** Not available.
- **Other Special Considerations:** Not available.
- **Created:** 8/11/2011
- **Last Updated:** 6/15/2015

The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.


# 3,450  SDS - TCEP.md
METADATA
last updated: 2025-12-14 RT after BA fixed inconsistencies
file_name: SDS - TCEP.md
file_date: 2020-12-29
title: Safety Data Sheet - TCEP
category: guides
subcategory: sds
tags: 
source_file_type: pdf
xfile_type: NA
gfile_url: NA
xfile_github_download_url: NA
pdf_gdrive_url: https://drive.google.com/file/d/189DnIKWpB47VrvaCwIgxdtrQpn8uPSHA
pdf_github_url: https://github.com/FocusOnFoundationsNonprofit/floodlamp-archive/blob/main/guides/sds/SDS%20-%20TCEP.pdf
conversion_input_file_type: pdf
conversion: ai (claude sonnet 3.5)
license: public domain
tokens: 3450
words: 2061
notes: 
summary_short: The Safety Data Sheet for TCEP (tris(2-carboxyethyl)phosphine hydrochloride, CAS 51805-45-9) provides hazard classification, first aid, storage, PPE, spill response, and disposal guidance for laboratory and synthesis use. It identifies the substance as strongly corrosive (causes severe skin burns and serious eye damage) and recommends strict protective equipment and locked, dry storage at 2–8 °C. The sheet also lists transport requirements as UN 3261, Class 8, Packing Group II (corrosive solid, acidic, organic, n.o.s.).


CONTENT

***INTERNAL TITLE:*** Sigma-Aldrich - Safety Data Sheet

**Version 6.4**
**Revision Date 12/29/2020**
**Print Date 07/31/2021**

## SECTION 1: Identification of the substance/mixture and of the company/undertaking
### 1.1 Product identifiers
- Product name: Tris(2-carboxyethyl)phosphine hydrochloride
- Product Number: C4706
- Brand: Aldrich
- CAS-No.: 51805-45-9

### 1.2 Relevant identified uses of the substance or mixture and uses advised against
Identified uses: Laboratory chemicals, Synthesis of substances

### 1.3 Details of the supplier of the safety data sheet
- Company: Sigma-Aldrich Inc.
- Address: 3050 SPRUCE ST, ST. LOUIS MO 63103, UNITED STATES
- Telephone: +1 314 771-5765
- Fax: +1 800 325-5052

### 1.4 Emergency telephone
Emergency Phone #: 800-424-9300 CHEMTREC (USA) +1-703-527-3887 CHEMTREC (International) 24 Hours/day; 7 Days/week

## SECTION 2: Hazards identification
### 2.1 Classification of the substance or mixture
**GHS Classification in accordance with 29 CFR 1910 (OSHA HCS)**
- Skin corrosion (Category 1B), H314
- Serious eye damage (Category 1), H318

For the full text of the H-Statements mentioned in this Section, see Section 16.

### 2.2 GHS Label elements, including precautionary statements
**Pictogram**

[Pictogram placeholder]

**Signal word**: Danger

**Hazard statement(s)**:
- H314 Causes severe skin burns and eye damage.

**Precautionary statement(s)**:
- P260 Do not breathe dusts or mists.
- P264 Wash skin thoroughly after handling.
- P280 Wear protective gloves/ protective clothing/ eye protection/ face protection.
- P301 + P330 + P331 IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.
- P303 + P361 + P353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/ shower.
- P304 + P340 + P310 IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a POISON CENTER/ doctor.
- P305 + P351 + P338 + P310 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER/ doctor.
- P363 Wash contaminated clothing before reuse.
- P405 Store locked up.
- P501 Dispose of contents/ container to an approved waste disposal plant.

### 2.3 Hazards not otherwise classified (HNOC) or not covered by GHS
None

## SECTION 3: Composition/information on ingredients
### 3.1 Substances
- Synonyms: TCEP
- Formula: C₉H₁₅O₆P · HCl
- Molecular weight: 286.65 g/mol
- CAS-No.: 51805-45-9

| Component | Classification | Concentration |
|-----------|----------------|---------------|
| Tris(2-carboxyethyl)phosphine hydrochloride | Skin Corr. 1B; Eye Dam. 1; H314, H318 | <= 100 % |
||

For the full text of the H-Statements mentioned in this Section, see Section 16.

## SECTION 4: First aid measures
### 4.1 Description of first-aid measures
**General advice**:
First aider needs to protect himself. Show this material safety data sheet to the doctor in attendance.

**If inhaled**:
After inhalation: fresh air. Call in physician.

**In case of skin contact**:
In case of skin contact: Take off immediately all contaminated clothing. Rinse skin with water/ shower. Call a physician immediately.

**In case of eye contact**:
After eye contact: rinse out with plenty of water. Immediately call in ophthalmologist. Remove contact lenses.

**If swallowed**:
After swallowing: make victim drink water (two glasses at most), avoid vomiting (risk of perforation). Call a physician immediately. Do not attempt to neutralise.

### 4.2 Most important symptoms and effects, both acute and delayed
The most important known symptoms and effects are described in the labelling (see section 2.2) and/or in section 11

### 4.3 Indication of any immediate medical attention and special treatment needed
No data available

## SECTION 5: Firefighting measures
### 5.1 Extinguishing media
**Suitable extinguishing media**:
Water, Foam, Carbon dioxide (CO2), Dry powder

**Unsuitable extinguishing media**:
For this substance/mixture no limitations of extinguishing agents are given.

### 5.2 Special hazards arising from the substance or mixture
- Carbon oxides
- Oxides of phosphorus
- Hydrogen chloride gas
- Combustible
- Development of hazardous combustion gases or vapours possible in the event of fire.

### 5.3 Advice for firefighters
Stay in danger area only with self-contained breathing apparatus. Prevent skin contact by keeping a safe distance or by wearing suitable protective clothing.

### 5.4 Further information
Suppress (knock down) gases/vapors/mists with a water spray jet. Prevent fire extinguishing water from contaminating surface water or the ground water system.

## SECTION 6: Accidental release measures
### 6.1 Personal precautions, protective equipment and emergency procedures
Advice for non-emergency personnel: Avoid inhalation of dusts. Avoid substance contact. Ensure adequate ventilation. Evacuate the danger area, observe emergency procedures, consult an expert.
For personal protection see section 8.

### 6.2 Environmental precautions
Do not let product enter drains.

### 6.3 Methods and materials for containment and cleaning up
Cover drains. Collect, bind, and pump off spills. Observe possible material restrictions (see sections 7 and 10). Take up dry. Dispose of properly. Clean up affected area. Avoid generation of dusts.

### 6.4 Reference to other sections
For disposal see section 13.

## SECTION 7: Handling and storage
### 7.1 Precautions for safe handling
**Advice on safe handling**:
Protect from moisture.

**Hygiene measures**:
Immediately change contaminated clothing. Apply preventive skin protection. Wash hands and face after working with substance.

For precautions see section 2.2.

### 7.2 Conditions for safe storage, including any incompatibilities
**Storage conditions**:
Tightly closed. Dry.

**Storage stability**:
Recommended storage temperature 2 - 8 °C

**Storage class (TRGS 510)**: 8A: Combustible, corrosive hazardous materials

### 7.3 Specific end use(s)
Apart from the uses mentioned in section 1.2 no other specific uses are stipulated

## SECTION 8: Exposure controls/personal protection
### 8.1 Control parameters
**Ingredients with workplace control parameters**:
Contains no substances with occupational exposure limit values.

### 8.2 Exposure controls
**Appropriate engineering controls**:
Immediately change contaminated clothing. Apply preventive skin protection. Wash hands and face after working with substance.

**Personal protective equipment**:
**Eye/face protection**:
Use equipment for eye protection tested and approved under appropriate government standards such as NIOSH (US) or EN 166(EU). Tightly fitting safety goggles

**Skin protection**:
This recommendation applies only to the product stated in the safety data sheet, supplied by us and for the designated use. When dissolving in or mixing with other substances and under conditions deviating from those stated in EN374 please contact the supplier of CE-approved gloves (e.g. KCL GmbH, D-36124 Eichenzell, Internet: www.kcl.de).

**Full contact**:
- Material: Nitrile rubber
- Minimum layer thickness: 0.11 mm
- Break through time: 480 min
- Material tested: KCL 741 Dermatril® L

**Splash contact**:
- Material: Nitrile rubber
- Minimum layer thickness: 0.11 mm
- Break through time: 480 min
- Material tested: KCL 741 Dermatril® L

**Body Protection**:
Protective clothing

**Respiratory protection**:
Required when dusts are generated.
Our recommendations on filtering respiratory protection are based on the following standards: DIN EN 143, DIN 14387 and other accompanying standards relating to the used respiratory protection system.

**Control of environmental exposure**:
Do not let product enter drains.

## SECTION 9: Physical and chemical properties
### 9.1 Information on basic physical and chemical properties
a) Appearance
   - Form: powder
   - Color: white

b) Odor: No data available
c) Odor Threshold: No data available
d) pH: No data available
e) Melting point/freezing point: Melting point/range: 175 - 177 °C (347 - 351 °F)
f) Initial boiling point and boiling range: No data available
g) Flash point: No data available
h) Evaporation rate: No data available
i) Flammability (solid, gas): No data available
j) Upper/lower flammability or explosive limits: No data available
k) Vapor pressure: No data available
l) Vapor density: No data available
m) Relative density: 1.041 g/cm³ at 25 °C (77 °F)
n) Water solubility: soluble
o) Partition coefficient: n-octanol/water: No data available
p) Autoignition temperature: No data available
q) Decomposition temperature: No data available
r) Viscosity: No data available
s) Explosive properties: No data available
t) Oxidizing properties: No data available

### 9.2 Other safety information
No data available

## SECTION 10: Stability and reactivity
### 10.1 Reactivity
The following applies in general to flammable organic substances and mixtures: in correspondingly fine distribution, when whirled up a dust explosion potential may generally be assumed.

### 10.2 Chemical stability
The product is chemically stable under standard ambient conditions (room temperature).

### 10.3 Possibility of hazardous reactions
Violent reactions possible with: Strong oxidizing agents

### 10.4 Conditions to avoid
No information available

### 10.5 Incompatible materials
No data available

### 10.6 Hazardous decomposition products
In the event of fire: see section 5

## SECTION 11: Toxicological information
### 11.1 Information on toxicological effects
**Acute toxicity**:
- LD50 Oral - Rat - 3,500 mg/kg
- LD50 Oral - Rat - 3,500 mg/kg
  Remarks: (External MSDS)
- Inhalation: No data available
- LD50 Dermal - Rat - > 3,000 mg/kg
- LD50 Dermal - Rat - 3,000 mg/kg
  Remarks: (External MSDS)

**Skin corrosion/irritation**:
No data available

**Serious eye damage/eye irritation**:
No data available

**Respiratory or skin sensitization**:
No data available

**Germ cell mutagenicity**:
No data available

**Carcinogenicity**:
- IARC: No ingredient of this product present at levels greater than or equal to 0.1% is identified as probable, possible or confirmed human carcinogen by IARC.
- NTP: No ingredient of this product present at levels greater than or equal to 0.1% is identified as a known or anticipated carcinogen by NTP.
- OSHA: No component of this product present at levels greater than or equal to 0.1% is on OSHA's list of regulated carcinogens.

**Reproductive toxicity**:
No data available

**Specific target organ toxicity - single exposure**:
No data available

**Specific target organ toxicity - repeated exposure**:
No data available

**Aspiration hazard**:
No data available

### 11.2 Additional Information
Not available

Material is extremely destructive to tissue of the mucous membranes and upper respiratory tract, eyes, and skin.
To the best of our knowledge, the chemical, physical, and toxicological properties have not been thoroughly investigated.

## SECTION 12: Ecological information
### 12.1 Toxicity
No data available

### 12.2 Persistence and degradability
No data available

### 12.3 Bioaccumulative potential
No data available

### 12.4 Mobility in soil
No data available

### 12.5 Results of PBT and vPvB assessment
PBT/vPvB assessment not available as chemical safety assessment not required/not conducted

### 12.6 Other adverse effects
No data available

## SECTION 13: Disposal considerations
### 13.1 Waste treatment methods
**Product**:
Waste material must be disposed of in accordance with the national and local regulations. No mixing with other waste. Handle uncleaned containers like the product. See www.retrologistik.com for processes regarding the return of chemicals and containers, or contact us there if you have further questions.

## SECTION 14: Transport information
**DOT (US)**
- UN number: 3261
- Class: 8
- Packing group: II
- Proper shipping name: Corrosive solid, acidic, organic, n.o.s. (Tris(2-carboxyethyl)phosphine hydrochloride)
- Reportable Quantity (RQ):
- Poison Inhalation Hazard: No

**IMDG**
- UN number: 3261
- Class: 8
- Packing group: II
- EMS-No: F-A, S-B
- Proper shipping name: CORROSIVE SOLID, ACIDIC, ORGANIC, N.O.S. (Tris(2-carboxyethyl)phosphine hydrochloride)

**IATA**
- UN number: 3261
- Class: 8
- Packing group: II
- Proper shipping name: Corrosive solid, acidic, organic, n.o.s. (Tris(2-carboxyethyl)phosphine hydrochloride)

## SECTION 15: Regulatory information
**SARA 302 Components**:
This material does not contain any components with a section 302 EHS TPQ.

**SARA 313 Components**:
This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313.

**Massachusetts Right To Know Components**:
No components are subject to the Massachusetts Right to Know Act.

## SECTION 16: Other information
**Further information**:
The above information is believed to be correct but does not purport to be all inclusive and shall be used only as a guide. The information in this document is based on the present state of our knowledge and is applicable to the product with regard to appropriate safety precautions. It does not represent any guarantee of the properties of the product. Sigma-Aldrich Corporation and its Affiliates shall not be held liable for any damage resulting from handling or from contact with the above product. See www.sigma-aldrich.com and/or the reverse side of invoice or packing slip for additional terms and conditions of sale.

Copyright 2020 Sigma-Aldrich Co. LLC. License granted to make unlimited paper copies for internal use only.
The branding on the header and/or footer of this document may temporarily not visually match the product purchased as we transition our branding. However, all of the
information in the document regarding the product remains unchanged and matches the
product ordered. For further information please contact mlsbranding@sial.com.

Version: 6.4 Revision Date: 12/29/2020 Print Date: 07/31/2021


# 1,507  SDS - Twist Synthetic SARS-CoV-2 RNA Control Rev7 001038v7.md
METADATA
last updated: 2025-12-14 RT after BA fixed inconsistencies
file_name: SDS - Twist Synthetic SARS-CoV-2 RNA Control Rev7 001038v7.md
file_date: 2015-06-12
title: Safety Data Sheet - Twist Synthetic SARS-CoV-2 RNA Control Rev7 001038v7
category: guides
subcategory: sds
tags: 
source_file_type: pdf
xfile_type: NA
gfile_url: NA
xfile_github_download_url: NA
pdf_gdrive_url: https://drive.google.com/file/d/1B5fQriqklnc_y3yi8kntGGb4s7Nj3HNZ
pdf_github_url: https://github.com/FocusOnFoundationsNonprofit/floodlamp-archive/blob/main/guides/sds/SDS%20-%20Twist%20Synthetic%20SARS-CoV-2%20RNA%20Control%20Rev7%20001038v7.pdf
conversion_input_file_type: pdf
conversion: ai (claude sonnet 3.5)
license: public domain
tokens: 1507
words: 862
notes: 
summary_short: The Safety Data Sheet for Twist Synthetic SARS-CoV-2 RNA Control describes a non-hazardous research-use reagent consisting of ≤1% RNA in TE buffer. It outlines prudent lab handling, first aid, spill cleanup, PPE recommendations, and storage at −80 °C. The sheet notes no transport restrictions and emphasizes disposal per local regulations and standard laboratory practices for materials of unknown toxicity.


CONTENT

***INTERNAL TITLE:*** Twist Bioscience - Safety Data Sheet

**SDS-001038**
**Revision: 7.0**

## SECTION 1: PRODUCT AND COMPANY IDENTIFICATION
### A. PRODUCT IDENTIFIERS
**PRODUCT NAME:** Twist Synthetic SARS-CoV-2 RNA Control  
**PRODUCT NUMBER:** 102019, 102024, 102860, 102862, 102917, 102918, 103087, 103511, 103512, 103513, 103514, 103515, 103533, 103907, 103909, 104043, 104044, 104338  
**SYNONYMS:** Ribonucleic Acid, RNA, Viral RNA Control

### B. DETAILS OF SUPPLIER OF THE SAFETY DATA SHEET
**COMPANY:** Twist Bioscience  
681 Gateway Boulevard  
South San Francisco, CA 94080  
**TELEPHONE:** (415) 216-8966  
**EMERGENCY PHONE #:** In the event of chemical emergencies: Contact CHEMTREC 24 Hour  
Emergency Telephone: In US: 1-800-424-9300;  
International number (Outside the US): +1-703-741-5970

### C. RELEVENT IDENTIFIED USES OF THE SUBSTANCE OR MIXTURE
For research and development purposes only.

## SECTION 2: HAZARD IDENTIFICATION
THIS PRODUCT IS CONSIDERED NON-HAZARDOUS. No components in this product, at the given concentration, are considered to be hazardous. Despite the classification of certain products/components as non-hazardous, we strongly recommend using prudent laboratory practices: avoiding unnecessary contact and use of personal protective equipment, which may include gloves, eye protection, and lab coats, during the use of any laboratory reagent. Twist Bioscience shall not be held liable for any damages resulting from handling or from contact with the above product.

## SECTION 3: COMPOSITION / INFORMATION ON INGREDIENTS
| Mixture | CAS Number | Percentage |
|---------|------------|------------|
| Ribonucleic Acid | N/A | ≤1% |
| TE buffer (Tris 10mM, pH 8.0, EDTA, 0.1mM) | N/A | 99% |
||

## SECTION 4: FIRST AID MEASURES
**SKIN CONTACT:** Remove contaminated clothing. Flush affected area with water and then wash with soap or mild detergent and water. Observe for signs of irritation. If irritation is present, get medical attention.

**EYE CONTACT:** Wash eyes with large amounts of water or normal saline for a minimal time of 15 minutes. If irritation isn't available, seek medical attention.

**INGESTION:** Get medical attention.

**INHALATION:** Remove from exposure area to fresh air immediately. Get medical attention immediately.

**INJECTION:** If accidentally injected, get medical attention.

**NOTE TO PHYSICIAN:** There is no specific antidote. Treat symptomatically and supportively as needed.

## SECTION 5: FIRE FIGHTING MEASURES
**Fire and Explosion Hazard:** None known to exist.

**Fire Extinguishing Media:** Dry chemical, foam, carbon dioxide or water. Warning: Take precaution not to aerosolize the powder, where it could become an inhalation risk.

## SECTION 6: ACCIDENTAL RELEASE MEASURES
**OCCUPATIONAL SPILL:** Wear appropriate protective clothing, safety glasses and chemically compatible gloves. Place contaminated material spillage in appropriate container for waste disposal according to site regulation. Wash contaminated clothing before reuse.

**REPORTABLE QUANTITY (RQ):** N/A

## SECTION 7: HANDLING AND STORING
Observe all federal, state and local regulations. Avoid contact with eyes, skin and clothing. Wash hands thoroughly after handling. Keep tightly closed. Store at -80 °C. Use good laboratory practices for handling and storage of chemical substances of unknown toxicity.

## SECTION 8: EXPOSURE CONTROLS / PERSONAL PROTECTION
**EXPOSURE CONTROLS:** Use good laboratory practices for handling chemical substances of unknown toxicity. Use in a laboratory hood or other ventilated device. OSHA, ACGIH, or NIOSH has not established occupational exposure limits for this substance.

**EYE PROTECTION:** Wear safety goggles to prevent eye contact with this substance.

**CLOTHING:** Wear appropriate protective clothing (laboratory coat with long sleeves) and equipment to prevent skin contact with this material.

**GLOVES:** Wear appropriate protective gloves to prevent contact with this material.

## SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES
**DESCRIPTION:** Clear, colorless, odorless solution  
**PH:** N/A  
**MOLECULAR WEIGHT:** Varies  
**ODOR:** None

## SECTION 10: STABILITY AND REACTIVITY
**STABILITY:** Stable under typical conditions of use and storage.  
**REACTIVITY:** N/A

## SECTION 11: TOXICOLOGICAL INFORMATION
**TOXICITY:** N/A  
**CARCINOGEN STATUS:** N/A

## SECTION 12: ECOLOGICAL INFORMATION
**ENVIRONMENTAL IMPACT RATING (1-4):** No data available  
**ACUTE AQUATIC TOXICITY:** No data available  
**DEGRADABILITY:** No data available  
**LOG BIOCONCENTRATION FACTOR (BCF):** No data available

## SECTION 13: DISPOSAL CONSIDERATIONS
Dispose of in accordance with federal, state and local environmental control regulations.

## SECTION 14: TRANSPORT INFORMATION
Ship as non-regulated material, no transportation restrictions apply.

## SECTION 15: REGULATORY INFORMATION
The toxicological properties of this material have not been investigated. For research and development purposes only.

## SECTION 16: OTHER INFORMATION
### POTENTIAL HEALTH EFFECTS:
**SKIN CONTACT:**  
Short Term Exposure: Possible Irritant  
Long Term Exposure: No information available

**EYE CONTACT:**  
Short Term Exposure: Possible Irritant  
Long Term Exposure: No information available

**INGESTION:**  
Short Term Exposure: Possible Irritant  
Long Term Exposure: No information available

**INHALATION:**  
Short Term Exposure: Possible Irritant  
Long Term Exposure: No information available

**INJECTION:**  
Short Term Exposure: No information available  
Long Term Exposure: No information available

THE AFOREMENTIONED INFORMATION IS BELIEVED TO BE CORRECT BUT DOES NOT PURPORT TO BE ALL INCLUSIVE AND SHALL BE USED ONLY AS A GUIDE. TWIST BIOSCIENCE SHALL NOT BE HELD LIABLE FOR ANY DAMAGE RESULTING FROM HANDLING OR FROM CONTACT WITH THE ABOVE PRODUCT.

## Supplier Information:
Twist Bioscience  
681 Gateway Boulevard, South San Francisco, CA 94080  
Email: customersupport@twistbioscience.com  
Phone: 1-415-216-8966

**Other Information:**  
Information provided herein is believed to be correct but is not deemed to be all inclusive and should only be used as a guide. Twist Bioscience should not be held liable for any damage resulting from handling or from contact with the above product.