In 1987, The Occupational Safety and Health Administration of the United States passed a law documented in the Code of Regulations (C.F.R. 29) under the section 1910.1200 stating the requirement to develop Material safety Data Sheets known otherwise as the "Right to Know Law". Recently, OSHA passed a revision to this law whose purpose is to further educate workers on the materials with which they come in contact. This new law called HAZCOM 2012 has been dubbed "The Right to Understand Law".

The new regulation is OSHA’s effort to come into harmony with the rest of the world on safety issues, specifically the United Nations’ Global Harmonized System of Safety (GHS).

In this OSHA regulation, the Material Safety Data Sheet has been modified to be in compliance with GHS and will now be expanded in its content and will be called "Safety Data Sheet" instead.

The content of the Safety Data Sheet will now include the following sections;

1. Identification
2. Hazard Identification
3. Composition Information
4. First Aid Measures
5. Fire Fighting Measures
6. Accidental Release Measures
7. Handling and Storage Guidance
8. Exposure Controls/Personal Protection
9. Physical and Chemical Properties
10. Stability and Reactivity
11. Toxicological Information
12. Ecological Information (non-mandatory)
13. Disposal Considerations (non-mandatory)
14. Transport Information (non-mandatory)
15. Reguolatory Information (non-mandatory)
16. Other Information (revision information, date, etc.)

The hazard will be divided into specific classes and assessments of the hazard severity is noted as noted as Danger or Warning.

The use of flavors will possibly cause confusion because with the new regulation, the presence of the flavor within the plant has a different exposure aspect than the flavor used in a food or beverage.

Flavors are so strong that the tiny amounts of the flavoring materials within the solvent system are extremely low and the final intended use is considered Generally Recognized as Safe by the Food and Drug Administration. So powerful are flavor components that some are perceived in parts per trillion (a desktop versus the map of the U.S. including Alaska), parts per billion (a drop of water in the whole body of a 747) or the weakest a part per million (an inch square postage stamp in a football field). These levels are obviously well below expected toxicity levels. In fact, flavors are so strong if we tried to taste them we would spit them out and could not even get them past our lips.

However, the flavor in its pure concentrated form can be harmful. The flavor should not be splashed in your eyes, it should not be ingested straight, and it should not be in direct contact with your skin. As silly as this sounds, these are the kinds of things the new OSHA regulation is meant to address.

In the future some flavors might have trace components that need to be labeled as dangerous. The findings upon which these conclusions are based represent repeated exposures and not one time accidents.

Nothing has changed, the flavors we love are still the same. Remember the flavor is a small component of your final system, therefore as I indicated above, the regulation most likely does not pertain to your retail product. In addition, safety has nothing to do with the source of the components. Natural or Organic compliant components can be hazardous just as well as their Synthetic counterparts because it is the chemicals that matter, and remember we, and the world around us are all made of chemicals.

All sample requests and flavor orders that you receive after June 1, 2015, will be accompanied with extensive paperwork (Safety Data Sheets) for each flavor. This information is intended to offer you proper handling guidelines and to keep you informed of any risks from mishandling or misuse.

All Safety Data Sheets should be kept in a safe and accessible place for easy access by you and your employees.

As with any new regulation requirements or changes, there is a challenging transition period. Flavor Dynamics, Inc has been preparing for this change over for several months. We appreciate your patience and understanding as more required documentation means more time needed for processing your requests.

If you have any questions about this or any other concerns, please call me at 800-271-8424

Dolf DeRovira
President
Flavor Dynamics, Inc.