Undisclosed chemicals — implications for risk assessment: A case study from the mining industry

Many of the chemicals used in industry can be hazardous to human health and the environment, and some formulations can have undisclosed ingredients and hazards, increasing the uncertainty of the risks posed by their use. The need for a better understanding of the extent of undisclosed information in chemicals arose from collecting data on the hazards and exposures of chemicals used in typical mining operations (copper, platinum and coal). Four main categories of undisclosed chemicals were defined (incomplete disclosure; chemicals with unspecific identities; relative quantities of ingredients not stated; and trade secret ingredients) by reviewing material safety data sheet (MSDS) omissions in previous studies. A significant number of chemicals (20% of 957 different chemicals) across the three sites had a range of undisclosed information, with majority of the chemicals (39%) having unspecific identities. The majority of undisclosed information was found in commercially available motor oils followed by cleaning products and mechanical maintenance products, as opposed to reagents critical to the main mining processes. All three types of chemicals had trade secrets, unspecific chemical identities and incomplete disclosures. These types of undisclosed information pose a hindrance to a full understanding of the hazards, which is made worse when combined with additional MSDS omissions such as acute toxicity endpoints (LD₅₀) and/or acute aquatic toxicity endpoints (LC₅₀), as well as inadequate hazard classifications of ingredients. The communication of the hazard information in the MSDSs varied according to the chemical type, the manufacturer and the regulations governing the MSDSs. Undisclosed information can undermine occupational health protection, compromise the safety of workers in industry, hinder risk assessment procedures and cause uncertainty about future health. It comes down to the duty of care that industries have towards their employees. With a wide range of chemicals increasingly used, there is a balance that needs to be reached between disclosure requirements, trade secret provisions and definitions of hazardous ingredients for market needs, and the information required to protect the health of their workers.