As product sourcing and formulations proliferate and organizations expand into new markets on a global scale, initiatives such as the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and the Registration, Evaluation and Authorization of Chemicals (REACH) add to the challenge of staying current with compliance requirements, including the proper management of material safety data sheets (MSDS) and labels. In addition to maintaining compliance with ever-changing and increasing agency-driven requirements, consumers expect complete transparency and a commitment to producing greener products.
Varying implementation and requirement timelines for GHS and REACH are a constant challenge. Both regulatory initiatives mandate comprehensive document updates to achieve compliance. The volume impact of the proposed OSHA GHS rule is estimated at nearly 1 million documents (MSDS). As a result, corporate strategies for managing MSDS are or have undergone significant modification. Comprehensive inventory management and data management partnered with capable, compliant and timely MSDS authoring are critical components of a REACH- and GHS-compliant MSDS management program.
Accurate chemical inventory management is the cornerstone of any comprehensive MSDS management program. Under REACH, obtaining and maintaining raw material MSDS and the full composition of mixtures helps companies identify the category individual substances fall into: manufactured within the EU, imported into the EU or purchased from a supplier within the EU.
Companies also must identify each substance’s tonnage and current classification. An equally important necessity is access to and evaluation of comprehensive product and substance level information. The sources for this data are far from singular, and the expertise required to interpret and evaluate critical classification (i.e. hazard determinations) requires time and expertise.
While authoring accurate and compliant MSDS always has been a mission-critical obligation, the advent of REACH and GHS bring new challenges. For higher volume substances, the company must attach an exposure scenario to the MSDS. The exposure scenario describes how the chemical can be used in a safe manner, with no risk, for the intended use. The exposure scenario either can be for each of the substances in the chemical product or for the mixture as such. Companies should obtain the necessary overview of the REACH regulation as it stands today and dissect how it relates to their chemicals and their supply chain. Manufacturers, users and distributors should be aware of not only their own obligations, but also their obligations to downstream customers and employees.
Choosing the Right Tools
Many companies are realizing that implementing GHS and REACH compliance activities into their organizations is no easy task. However, there are tools available to help companies manage the increasingly complex and changing global chemical regulatory obligations associated with GHS and REACH.
For example, there are several content tools on the market that can be used to feed chemical regulatory data into corporate EHS and MSDS authoring systems. These integrated data tools provide efficient change management and regular updates as regulations change and new versions are released. These tools can help ensure correct, consistent GHS classification and labeling according to the UN purple book and also take into consideration the national deviations and other nation-specific regulations. Document templates for producing MSDS, labels and other hazard communication documents and multi-lingual phrase libraries also are available.
Companies also may choose to employ outsourced services for their GHS classification of substances and mixtures as a separate service or as part of outsourcing MSDS and label authoring.
In-house MSDS authoring staff may want to consider upgrading to an authoring platform that will help generate hazard communication documents to meet GHS-related international regulatory compliance and business requirements. This platform should provide full support for hazard communication and classification and labeling requirements to generate globally compliant MSDS and label documents. The system should accommodate the requirements outlined in the GHS, consisting of the classification of substances and mixtures according to their health, environmental and physical hazards and hazcom requirements for labeling and MSDS.
For inbound vendor MSDS management, users will want to search, print, view and email vendor and raw material MSDS in a company-specific database via a Web browser interface. As GHS requirements increase the burden of vendor MSDS management, a robust MSDS management system can help reduce the time and resources necessary for effective compliance management. Employee training will be required to familiarize those who use, store and transport regulated materials with the changes in format and content.
Creating, analyzing and managing globally compliant MSDS, product label content and hazardous materials transportation documents that reflect both GHS and REACH requirements can be extremely challenging. Strong processes, applications, systems and service providers are needed to support the various aspects of compliance management. Now might be the right time for organizations to evaluate their MSDS and labeling compliance programs, as a stand-alone operation or part of the greater whole (overall chemical management compliance). Scrutinize your current processes, evaluating and identifying compliance gaps. Create a comprehensive new policy or revise your existing policy to reflect impending regulatory change. Sell it as a priority so that all levels of the organization have and maintain a strong sense that the company places top priority on compliance with internal EHS policies.
One aspect that often is overlooked, but is critical to performance, is budget allocation. Squeezing dollars out of an existing budget is a tough task. So, as we near fiscal year end, proactively approach the subject of the dollars that will be required to maintain compliance.
Kami Blake is a solutions engineer with 3E Co. In this role, she provides technical expertise to assess regulatory requirements, information management technology and analysis of existing hazmat programs to develop compliance solutions. Tamie Webber has worked in product management at 3E Co. for several years and is responsible for product management initiatives, product planning and strategies and product development for 3E’s product line, including MSDS distribution and management, emergency response, regulatory reporting, training and waste services.