Hello All,

In an earlier post I questioned why the Maine State Apiarist would use the word DANGER when describing Apivar.  Well I now know.  It is on the package label, however, I still feel this incorrect.  I can only imagine what the folks at Brushy Mountain went through to get Section 18 approval from the EPA ,something for which I am truly grateful.  Based on my own experiences I would bet it was somewhere close to a root canal without anesthesia.

Hazardous materials are required to have product warning and precautionary labeling.  This includes statements of hazard (e.g. Toxic, Flammable), precautionary advice (Use with adequate ventilation), first aid, and signal words.  The signal words are specific:  DANGER, WARNING and CAUTION.  The use of these is very prescriptive.  DANGER is used for Toxic, Corrosive, Flammable, etc.  It is also used  for carcinogens and reproductive toxins.  In the US a toxic substance is defined as something having an LD50 between 50 and 500 mg/kg.  Pure Thymol has an LD50 of 980 mg/kg, almost double the toxic definition cut off.  (When using LD50 data the lower the number the more toxic a substance is.)  One has to be very careful when assigning hazards due to the downstream effect.  The more hazardous a material is the greater the precautions necessary to handle.  Fire and building codes use certain data points when establishing requirements for storage and handling. The difference between a Highly Toxic" and a "Toxic" substance could result in much different requirements and the associated costs.

There may be some reasons that I am unaware as to the Danger statement, however overstating the hazard can almost be as bad as understating it.  The incident in Maine is a good example of how this can cause confusion.  If I had previous knowledge about Thymol and someone told me that coumaphos carries a lower signal word I could wrongly assume that coumaphos is less toxic.

I have been involved with hazard communication most of my career.  Substance classification is difficult at best given all the different aspects that contribute to the hazard and the regulatory requirements.  Twenty years ago Material Safety Data Sheets were written with the assumption that the reader would have a technical background.  Ten years ago the push was to use the MSDS for a wider audience and it was recommended that they should be written to a level of understanding of a seventh grade education.  In all the years I have be working in this area a few facts have come to light.  The one label that is routinely read by the widest audience is the one found on the box of cereal on your breakfast table, and that the only individuals that really read labels are lawyers and regulatory agents.

Sorry to belabor this point but maybe it will prompt you to read the label and consider what it is saying.

Bee Safe,

   Ron

Ron Bogansky
Kutztown, (eastern) PA, USA



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