SDS Management Is Hard A Prescription for Managing SDSs in the World of GHS

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Contents Introduction ..................................................................................................................... 2

Catalysts for a Global System ......................................................................................... 3

The Globally Harmonized System for Classification and Labelling of Chemicals (GHS) . 5

How Was GHS Adopted? ................................................................................................ 7

GHS Adoption and Business Impact ............................................................................... 8

GHS and Business Impact in the Real World .................................................................. 9

Driving Compliance (SDS Management in the Real World) .......................................... 12

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Introduction

Companies large and small have always struggled with managing Safety Data Sheets

(MSDSs/SDSs) and the information about chemicals on these documents. Local, federal

and industry-specific regulations are complicated. Adding mergers and acquisitions,

changes to products, varied regulatory agency requirements and shifts in other identifying

information further complicates processes, making authoring and managing SDSs a

universal challenge.

The adoption of the Globally Harmonized System of Classification and Labelling of

Chemicals (GHS), although well intended, continues to create more complications for

those involved in authoring and managing SDSs. If you’re involved in hazard

communication (authoring or managing SDSs), the changes to SDSs outlined by GHS

may be clear but what do they look like in practice? You may question the SDSs you’re

receiving, what products they relate to and what documents (MSDSs) they replace.

You’re not alone. This review of SDS management in the world of GHS explores the

catalysts for GHS, the impact of its adoption and the additional complications it adds to

authoring and managing SDSs. In addition, it will offer unique insight and

recommendations to mitigate and ease the global transition to GHS.

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Catalysts for a Global System A Global Supply Chain

Most businesses are a part of the global supply

chain. For example, the United States

International Trade Commission shows a steady

increase in foreign content found in products

manufactured in the United States over the past

40 years. In short, the ingredients of a product

can originate from almost anywhere in the world.

To protect workers, consumers and the

environment, understanding what is used in

products or their production is a global concern.

Increased Consumer Awareness

Consumer awareness and concern about the health and environmental impact of

products increases and influences the use and regulation of ingredients. A report

published by IEHN, Public Awareness Drives Market for Safer Alternatives: Bisphenol A

Market Analysis Report, concludes that despite “announcements by industry officials and

the U.S. FDA that BPA (bisphenol) may be safe for consumers, the market for BPA-free

products continues to expand as consumer awareness of links between BPA and rising

health issues grows.” The report goes on to explain that consumer behavior around

products and their ingredients moves faster than legislation. But it is a key driving factor

to emerging regulations.

Non-Standardized Regulatory Landscape

Before GHS, regulatory agencies mostly operated autonomously. They classified

chemicals, defined hazards and determined hazard communication with their specific set

of regulations—differences varied from region to region. Disharmony resulted in a

tapestry of confusing pictograms, hazard statements, signal words, exposure limits and

other identifiers, making it difficult to express this critical information to the global market.

These regulatory systems ultimately had the same purpose. However, with little or no

consistency among them (classification criteria, methods to convey hazard information,

exposure limits, etc.) the complexity and business cost in the global market was

prohibitive. Furthermore, regarding the health and safety of employees and consumers,

these systems were sorely out of date.

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Let’s take a look at the common example of Acetone to examine how three different

agencies presented chemical information on the same product:

Canada’s regulation prior to the adoption of GHS (WHMIS 1988) included round pictograms and alpha-numeric classifications such as the B-2 and D-2B show here. Note the pictogram with what seems to be a ‘T’ and an exclamation mark combined.

In the former European Union regulation, the Dangerous Substance Directive (EU DSD) provided criteria for classification and labeling of substances. It included square pictograms and Risk phrases, like the R11 and R36 shown here. The R-phrases were basically the classifications. This regulation also included Safety phrases (S-phrases) like the S2 and others shown. Here the second pictogram includes a black “X” which is different than the WHMIS 1988 pictogram above. This was another way that differing hazard information would appear on MSDSs and labels prior to the adoption of GHS.

The former version of OSHA’s Hazard Communication Standard (OSHA 1994) included no requirements for any specific pictograms or classifications on MSDSs or labels. The manufacturer, distributor or supplier determined how that information would be represented. This is a stark contrast to the WHMIS 1988 and EU DSD information above. In the example provided, the set of information on the hazards of this substance only includes text—quite a bit more text than the other two systems.

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The Globally Harmonized System for Classification and Labelling of Chemicals (GHS)

The goal of GHS is to standardize the classification rules for hazard communication,

safety data sheets (SDSs, formerly MSDSs) and chemical labels at the global level.

A Snapshot of GHS

• Developed by the United Nations (UN)

• Mandated in 1992 at the United Nations Conference on Environment and

Development (UNCED)

• Based on existing systems (U.S., E.U., Canadian and U.N. TDG)

• Includes classification criteria and hazard communication elements for hazard

classes and categories

• Published first edition of the system in 2003 and most recent—the sixth revision

(Purple Book)—in 2015

• Adopted by 72 countries

Proposed Benefits

Make all systems consistent for workers handling hazardous chemicals

Reduce costs to governments and companies complying with different systems

Enable better communication of chemical information

Protect workers

Increase international trade

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Regulatory, À La Carte

GHS was designed in such a way that regulatory agencies

could adopt the hazard classes, categories and

classification criteria by taking the pieces that fit best into

their existing regulatory frameworks. This “building block”

approach enables agencies to better control the potential

impact triggered by a complete reconstruction of their

hazard communication systems. For regions with less

mature or non-existent regulatory frameworks GHS offers

a blueprint for success.

What UN GHS Is Not

There are some important differences between GHS (the system developed by the United

Nations) and the regulations put into place by agencies incorporated the system.

Until the GHS criteria are adopted by a regulatory body (OSHA, CCOHS, etc.) there is no binding obligation to use the criteria.

While GHS covers a large number of hazards, there are some hazards that it does not yet address (combustible dust, static accumulator, metal fume fever, simple asphyxiant and others).

GHS is a living document and a new edition is published every two years. Each revision has amended both existing hazard classes and added new hazard classes.

That’s right! The Globally Harmonized System for Classification and Labelling of Chemicals isn’t actually that harmonized. This disharmony creates bigger challenges to managing SDSs and chemical data across the global supply chain.

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How Was GHS Adopted? An Adoption Snapshot: Occupational Safety and Health Administration (OSHA)

OSHA adopted GHS by updating OSHA’s HazCom Standard (HCS) as “OSHA 2012.”

OSHA 2012 included the following elements:

• Most GHS hazard classes and categories

• Some unique OSHA-only extras that were outside the scope of GHS i.e., simple asphyxiant and combustible dust

OSHA’s adoption of GHS also added other new requirements to OSHA HCS:

• Prescribed hazard communication elements based on classification

• Standardized SDS format

• Additional information on SDSs

• More stringent cut-offs for mixture classification–no longer the straightforward 0.1% carcinogen and 1% thresholds for all other hazards

As you can see, the United States didn’t fully adopt UN GHS. Instead, OSHA utilized certain parts (the building block approach) and added their own criteria in OSHA 2012.

Differences Emerge

The flexible global adoption of GHS (such as in OSHA’s adoption) has fractured the forecasted harmonization, creating unexpected outcomes. Disharmony can be found in pictograms, hazard phrases and classification criteria. In the example below you can see the differences in OSHA 2012 and EU CLP criteria:

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GHS Adoption and Business Impact

Manufacturers/Distributors/Suppliers

• Authoring SDSs for all products to comply to updated regulations

• Create new labels to comply to updated regulations

Employers

• Obtain new SDSs for all products used

• Training employees on new regulations

• Create new labels to comply to updated regulations

By the Numbers

The implementation of GHS in the U.S. was estimated to have the following impacts:

• Affect 1 million documents for about 1 million chemicals

• Affect 5 million+ workplaces

• Affect 40 million + workers

• Cost $97 million a year during adoption

The implementation of GHS in the U.S. was expected to have the following cost savings and safety outcomes:

• Cost reduction of $266 million per year

• Prevention of 43 fatalities per year

• Prevention of 585 injuries and illnesses per year These cost reductions and productivity improvements equal $585 million per year and OSHA estimates a net annual savings of $754 million per year from the proposed revisions. So, the estimated $97 million per year to implement GHS in the U.S. is actually12.8% of the annual cost savings.

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GHS and Business Impact in the Real World In the MSDS to SDS conversion (to GHS) companies often had to make business decisions to get documents authored within the confines of the multi-year transition period. These business decisions have consequences for SDS management downstream. Here are some of the Business decisions related to SDSs:

Manufacturers/Distributors/Suppliers

Authoring SDSs does not equal SDS management and decisions made in the authoring process impact how they are being managed at all points.

To save money on the cost of authoring SDSs in some cases, like paint, business combined multiple SDSs into one SDS.

In other cases, because of criteria and classifications, products that might have been on a single SDS were split into many and similar materials appear on the same SDS.

Businesses changed the method or the software used to author SDSs and in some cases, there are missing product codes or the data wasn’t migrated in time.

Authoring is independent of product packaging, the SDS is created and then the label and the product are packaged—leading to differences in product identification.

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Employers

Multiple MSDSs become 1. No matter if you’re managing your SDSs in a paper binder or electronically, you have the challenge of matching and tracking associated SDSs.

Upstream authoring decisions can drive the consolidation of SDSs so that 1 SDS becomes multiple SDSs. Although this may present a cost savings for the author this increases the level of complexity for managing SDSs.

During the conversion from MSDSs to SDSs material identifications differ, making it difficult to appropriately associate the document with the material on site.

Differences in how product information relates to the SDS.

Gaps in label generation and practical application require additional attention to match the correct SDS and label to the product and its packaging on site.

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Common Questions

Q: Why are our documents not GHS-compliant? A: Manufacturer/Distributor business decisions result in revised documents that may not have a 1:1 relationship with the MSDS they should replace. The replacement SDS does not always line up clearly with the previous MSDS. In addition, in the U.S., materials discontinued prior to June 1, 2015 do not require a SDS. If a material was not manufactured after June 1, 2015 the manufacturer has no obligation to update a SDS. Documents are separate from the product (in OSHA regulations, the SDS must match the label). After the transition, workplaces may find it difficult to find a true SDS match.

Q: What are these new hazards on our raw materials? A: New GHS hazards and threshold changes. Q: Safety Data Sheet is at the top of the document. Does that mean it’s updated? A: No. A header on a document does not mean that a document has been updated to be compliant. Q: I have 3 vendor SDSs for nitric acid–but they all have different information in section 2. What’s going on? A: Something that has become common after the adoption of GHS is that the same substance may have different classifications. A 2015 study compared 17 different supplier SDSs for 50-70% nitric acid. The researchers found 17 different sets of classifications. Not only is GHS adoption not harmonized across regulatory bodies that have adopted GHS, classifications for substances can’t be expected to be consistent across vendors. As professional judgement is used in determining classifications and these vary, this professional judgement contributes to the lack of harmonization. Q: Does the SDS state that it is GHS compliant? A: No. It’s not always obvious that an SDS is compliant and it does take some level of professional judgement to make that determination.

Q: I have the same number of materials but my SDS collection continues to grow. What’s happening? A: The changes brought on by the GHS coupled with the ever-evolving way that vendors choose to author documents means that most workplaces must take an active role in managing SDSs, even if they utilize a software solution. The industry-wide challenge of lining up an SDS document with the products and chemicals it represents is now compounded by adding the necessary step of reviewing to see if the new document replaces the existing document wholesale or if you must keep both SDSs actively because the updated document has been changed in a way that the new document doesn’t have all of the information you need for the products that you store and use.

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Driving Compliance (SDS Management in the Real World) More than ever, companies must take an active role in managing chemical inventories and SDSs. No matter what method you use to manage SDSs and other supplemental documentation (paper binders, spreadsheets, homegrown solution or SaaS solution) there is no silver bullet, no magic elixir, no cure to avoid having to be actively manage SDSs. Although there isn’t a cure for the complications related to GHS yet, below is a recommended therapy plan for driving compliance:

Annual Check-Ups

These may not be on the top of your list of favorite things but these annual activities can help you avoid minor problems becoming big issues.

Perform Regular Inventories

Inventory each area and facility to understand what products you need to match with SDSs and associated documents. SiteHawk recommends performing an inventory every 12-18 months to evaluate if any materials have been brought on site without the necessary documentation. Reconcile the list of materials from the inventory (including the chemical area, manufacturers and product codes) with the SDS collection to see what products need a SDS.

Contact Vendors to Request SDSs

After an inventory, most companies find products that don’t have a SDS on record. The list of materials, manufacturers and product codes collected during the inventory are the starting point for acquiring a SDS. SDSs can be found in different ways:

• Web search

• Manufacturer website

• Contacting the manufacturer by phone or email When requesting a SDS, it is important to have the right information so that the SDS you receive accurately matches your product. SiteHawk recommends that you collect, at a minimum, the following from the product label:

• Product name

• Manufacturer name

• Product code

• Barcode/UPC

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Some products look similar and may have a differently-colored labels or similar subtitles such as “Technical Grade” versus “Professional Grade.” The more information you can collect, the better.

Review Company EHS Goals with Vendors

Whether it’s a chemical company or the EHS software partner, review your goals with them so that they can improve the data they include on SDSs or the functions in the software you use.

Ongoing Maintenance

Hiring a SDS and chemical data management company and assuming that everything will be done (as if by magic) is similar to thinking that getting a gym membership without going makes a healthier person. In both cases, the more effort given, the more satisfied one will be. Here are some tips for ongoing chemical data maintenance and compliance health.

Institute a Chemical Approval Process

A chemical approval process helps maintain upstream and downstream communication about what is arriving on site. Preventing the purchase or use of restricted materials on site begins with a chemical approval process that is supported and promoted from the top of an organization. This process also ensures that the correct documents and associated paperwork are onsite with materials, driving risk management to avoid fines and confusion.

Ask Questions

If you are unclear about the SDSs you receive, ask the vendor or supplier. Vendors are working diligently to comply with the new regulations and provide documents in a timely manner. Like you, they experience challenges with the GHS transition Questions to Consider

• What has changed from the previous version of this SDS? Although Section 16 on a SDS should indicate changes, not all of them may be represented.

• What products (product codes) does this SDS cover?

• Does this SDS reflect more or fewer products than the previous version?

• Is this GHS (OSHA 2012, WHMIS 2015, etc.) compliant?

• How often do you update product SDSs? Some companies update quarterly or when regulatory or formula changes are made.

Submit all SDSs to Your SDS Management Company

When using SDS management software, submit all SDSs every time you receive them. This keeps your collection up-to-date and helps maintain efficient reporting in your organization.