OSHA Status: PENUMBRA-7™ is not a chemical. The Hazard Communication Standard technically does not apply. This SDS was prepared voluntarily following the complaint volume received after the April 2024 total solar eclipse, during which a statistically significant number of observers were in the penumbral zone despite having access to accurate maps showing the path of totality. We felt something needed to be said formally.
EPA Status: Not a pollutant. Not a contaminant. Will not appear on a Superfund site list. Is a shadow. The EPA reviewed a preliminary inquiry in 2020 and responded that this was "not an environmental issue in the regulatory sense" and that they "appreciated the creativity" of the inquiry.
EU Regulatory Status: Under proposed EU Directive 2024/1188/EC on Astronomical Phenomenon Disclosure (in committee; not yet adopted; expected 2028 at earliest), PENUMBRA-7™ would require disclosure at point of sale as "not totality." The designated point-of-sale is outdoors. The sky is the disclosure mechanism. The sky is already disclosing it. The directive may be redundant.
California Proposition 65: The State of California has not determined that penumbral exposure causes cancer or reproductive harm. The State of California has, however, expressed concerns about many other things, including several that are also not chemicals. Users in California should consult their county eclipse guidance addendum, Form ECL-2024-P, available from county agricultural extension offices in counties that have agricultural extension offices, which is not all counties.
Legal Note Regarding Liability for the April 2024 Eclipse Complaint Volume: The entity responsible for the path of the eclipse — specifically, the Moon — has no legal mailing address, no registered agent, no domicile for service of process, and is not incorporated under the laws of any jurisdiction. Seventeen letters were sent. None were delivered. This is not a postal error. All pending litigation arising from penumbral dissatisfaction is noted and is unlikely to be resolved.