Streamlining Compliance

Global compliance can be a daunting task for chemical manufacturers. California-based 3E Co. seeks to simplify the process.

For a chemical manufacturer seeking to become a global supplier, keeping up with numerous foreign safety regulations and requirements can be quite a challenge. MSDgen®, a compliance tool from Carlsbad, Calif.-based 3E Co., was created to streamline one important aspect of this process, the creation and distribution of Material Safety Data Sheets (MSDSs).

“The challenge that our clients are faced with is keeping current with global compliance,” said Karen Lanka, director of HSE Systems Client Services at 3E.“Many authors find that even though they have the United States regulatory knowledge, as their companies expand into the marketplace internationally, they find it difficult to be knowledgeable with the requirements for other regions.”

MSDgen is powered by ARIELTM, 3E’s chemical and regulatory database, which consists of a massive, aggregated collection of lists, legislation, and compliance guides for regulated chemicals throughout the world at multiple levels of jurisdiction, including REACH. Other data sources are supported, such as ChemADVISOR (LOLI), if the user prefers.

A Three-Step Process
The first step for MSDgen users is to create a chemical formulation within the system by specifying which substances will be used and the appropriate percentages for each. Once the complete formulation is entered, MSDgen automatically performs various classifications of the substances, such as the Acute Toxicity Estimate.

“MSDgen will do that, and it will cite the Purple Book and explain exactly how it made that calculation,” Lanka said. “It will show you how it estimated some of the EqualToX value for fish toxicity. It will estimate Dis-Chem properties, the boiling point, the flash point, auto-ignition temperature, and it will explain why it calculated what it did. This all happens simply by entering the ingredients and their appropriate percentages. We’ve done nothing else to the material at this point, yet we have these assessments.” These assessments, as Lanka pointed out, are estimates and are flagged as such. At any point, as may be required, users can enter in their own test data.

After the MSDS author has reviewed the information and made any change necessary, the next step is to run MSDgen’s rules, which will author the qualitative statements required throughout the MSDS document based on the product’s classification assessment. “For example, it might assign ‘Wash hands thoroughly after handling’ or ‘Immediately flush eyes with water for 15 minutes’—things like that,” Lanka said.

Depending on a client’s needs, MSDgen’s rule sets are available for numerous countries and their regulatory bodies, such as Canada (WHMIS), EU, the United States (OSHA, ERG, HMIS III®, NIOSH, RCRA), and more. Because these rules can be very numerous depending on the client’s needs, this second step can take an extended amount of time. As a solution, users can elect to complete this option in batch mode and continue on to another formulation. “You could submit this to batch, let it run overnight, and when you arrive in the morning, the rules are going to be done and you could look at your documents at that point,” Lanka said.

One of the software’s many bonus features, its “Trade Secret Disclosure Management” option, will become apparent at this point. This allows users to customize or restrict the printed name of certain ingredients, thereby protecting the manufacturer’s proprietary formula information while still ensuring correct hazards are communicated. “It will mask the name and the CAS number, so anybody reading the MSDS will not know what the actual chemical is,” Lanka said. “You still have to show appropriately the hazards of that ingredient. MSDgen is giving you the tool so you can handle it automatically and easily.”

The final step in the process is to finalize the MSDS into a PDF format for printing and distribution. “We freeze the data,” Lanka said. “At this point, the user will not be able to update it directly. The reason for that is to preserve the integrity of these documents.” One major advantage of this is that if it becomes necessary, the author can later go back and produce a new language translation from the original PDF without fear of the data’s changing.

Compliance Updates
But the MSDSs are not completely static. As part of 3E’s subscription service, MSDgen sends quarterly ARIEL updates and will flag the affected parts of a client’s MSDS inventory. Clients can choose to dismiss or approve any affected MSDS item change they feel necessary and then finalize a new MSDS for that product.

As an added bonus, MSDgen is configured to work through a client’s internal or external interface to make those MSDSs more available. “We have a feature called individual file generation, and what that will do is take the PDF files that MSDgen has created and dump them into a separate folder outside of MSDgen, someplace where possibly external pages or other pages can pick those up,” said Mark Garlow, project manager at 3E, who noted this feature allows users to host their MSDS internally or externally for employee or customer access.

This brief overview of the feature-rich MSDgen is a small sample of its numerous capabilities. For complete information, visit www.3ecompany.com.

This article originally appeared in the January 2009 issue of Occupational Health & Safety.

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