New Advances in Global SDS Management

Before rolling out any management system, communicate your plans with all stakeholders, detailing the benefits and how it will affect their work tasks.

• By Louise Bernstein
• Sep 01, 2012

Managing global environmental, health, and safety (EH&S) management can be an intricate tightrope walk with many challenges lurking to disrupt its delicate balance. Potential obstacles include evaluating differing global strategies, managing changing regulations, varying local resources and expertise, local infrastructure, and cultural considerations.

With these considerations in mind, taking a corporate global safety data sheet (SDS) management strategy and implementing it locally can seem daunting. However, with a thorough understanding of why global SDS management is so beneficial, knowledge of best practice methods for developing a system, and a few tips for circumventing common pitfalls, this worthwhile process can be dramatically streamlined.

Global SDS Management
Let's first describe what global SDS management means. It is a set of corporate guidelines, coupled with a comprehensive management system to handle a company's SDSs for all global locations. SDSs are stored, viewed, and downloaded from a centralized access point, in addition to document management and supplier relations procedures designed to ensure there is an SDS for every product on site, and those SDS are kept current. The application and supporting resources should to be synchronized to ensure success.

Reasons for Global SDS Management
Once a global system is in place, many corporate and local advantages are achieved. These rewards justify the collaborative effort of rolling out such a comprehensive system.

• Compliance Administration. Compliance is at the heart of any SDS management system. Organizing this through one system allows for centralized administration to ensure local and corporate due diligence.
• Centralization. One system for all locations and departments allows for inventory, data, and SDS consolidation and corporate transparency.
• Productivity. Removal of task replication between locations and reduction of overall SDS management effort enables employees to a focus on other tasks.
• Cost Reduction/Avoidance: Increased overall efficiency removes operational costs, and increased compliance lowers exposure to regulatory body fines, employee lawsuits, and the compromising of a company's PR and brand.
• Data repository. A large repository of SDSs and product data will be quickly amassed. The centralized data and SDSs can be funneled into regulatory tracking (GHS/CLP, REACH, RoHS...), supply chain analysis, and integration with internal tools (Authoring, BOM, Purchasing ...).

Global SDS Management, Implementation Process
The process follows this six-step process: Research current systems, Regulatory awareness, Select system, Standardize & localize, Communicate, and Phase rollout.

1. Research Current Systems. There is usually a large variance of systems in place already -- paper-based, Access/Excel, third-party applications, and applications built by in-house IT teams. How those systems are used and the documents and data held within these systems will need to be included in your transition evaluation. Additionally, the people in charge of those systems will be the cornerstone of local adoption for your new system, so engage their expertise.

2. Regulatory Awareness. The next portion is being aware of the regulations involved and your responsibilities within each country. While elements of SDS management are similar throughout the world, there are country-specific requirements which should be accounted for in any new program. Some examples:

• Languages: Ensure employees have access to SDSs in local languages, possibly multiple languages per location, which can be the case in Canada or Belgium.
• Suppliers' updating obligations: A supplier's obligation to downstream users differs in relation to when it needs to re-author or send an updated SDS. In the United States, an SDS needs to be updated within 90 days when there are significant changes to its information. In Canada, an SDS needs to be updated every three years regardless if there are changes required. In Europe, it needs to be updated as soon as possible and sent to customers that have purchased the product within the last 12 months. The United States and Canada have no requirements for suppliers to provide revised SDSs to previous customers in the absence of subsequent sales.
• EU REACH: European extended SDSs can have multiple Exposure Scenarios attached, creating documents of up to hundreds of pages long. Your system should handle documents of this size. In addition to this, while the law states that Exposure Scenarios are to be incorporated into the SDS, it isn't often the case in practice. Employees should learn how to load Exposure Scenarios with associated SDSs.
• Safety Cards: Many countries (the United Kingdom, Germany, etc.) require employees to access Workplace Safety Cards with SDS.

3. Select System. Once you are aware of local regulatory responsibilities, you can start the process to select or build an appropriate system to fulfill those needs. There are several essential factors to incorporate into your evaluation:

• One accessible SDS access point for management and employees. A best practice is using an intranet or Internet portal. A secondary access point is advisable should the first become unavailable. Examples of secondary access points are CD-ROM, FTP, phone request (for email/fax), and paper binders.
• Support for the wide breadth of country-specific regulations, easily adapting when those regulations inevitably change -- handling Exposure Scenarios in Europe, for example.
• Multilingual capabilities so local employees are encouraged to use the system. A multilingual requirement applies to interface localization and also storing data in many languages. In short, Japanese employees should be able to search within a Japanese interface to retrieve a Japanese SDS.
• Finally, as a company grows, the system should scale with it. New locations should be added easily, and the technology must be flexible. IT resources and application infrastructure should support the application long term, and the system should have the capacity to handle an ever-increasing volume of data.

4. Standardize and Localize Management Plan. Now that you have your system chosen, you can develop your management plan.

Centralization of procedures, data, and technology is the main driver behind a global program. Yet some room should be retained for decentralization of day-to-day management. The foundation to any rollout is a "train the trainer" approach to ensure local management are knowledgeable and empowered to handle the day-to-day running of your program. Handling of daily questions or transactions through a small corporate team can be overwhelming and time-consuming, resulting in a bottleneck of communication, especially when differing time zones and languages are involved. Local management will have a better understanding of local needs and can respond quickly while basing its response on corporate guidelines. Once local management is empowered with some system ownership, there will be motivation to encourage employee adoption and increasing the speed of that adoption.

5. Communication. The most successful transformations of any business process occur when management mobilizes employees by communicating objectives clearly and early in the process. This is especially true when management engages employees at all levels, from top management to the front line. Before rolling out any system, communicate your plans with all stakeholders, detailing how it will affect their work tasks, and importantly, outline the overall benefits.

6. Phase the Rollout. A phased rollout allows a company to tailor the implementation to specific audiences. Each group may require a slightly different approach. With so much at stake and many moving parts, taking the time to group locations into phases can circumvent potential pitfalls and encourage adoption. Lessons can be learned and brought into the next grouping. Depending on resources, and rollout deadlines, groups can be rolled out in parallel.

A phased approach can be segregated by number of factors, including:

• Geographies. Implementing by geographies is the most commonly used approach. Companies like to implement by country or continent because time zones, languages, and regulatory requirements are the same, or similar. Logistically, it is easier to travel between locations throughout the duration of their implementation due to their close proximity.
• Business unit/location groups. Grouping business units or locations with similar purposes together is the second-most-popular method because these locations have a similar purpose and management teams usually know one another, so there is already a sense of cohesion. Business units have similar products because they are focused on a particular part of your company and, even better, possibly share EH&S polices or even a legacy system that can be replaced at the same time. Location group examples would be all R&D laboratories or all distribution centers.
• Regulatory landscape. Regulatory requirements are a grouping mechanism, particularly for countries in the throes of adopting GHS (or REACH in Europe). They may require immediate implementation attention to ensure systems are in place to ensure compliance before regulatory transition periods are over. Locations using paper-based systems will require hand-holding to adopt a centralized, automated system. Technology will be a new concept, and therefore an additional layer of implementation effort, such as installing workstations and ensuring computer literacy, is required. Grouping by current systems also would apply should locations use a third-party application and their contract is due to expire.
• Current systems. Lastly, implementing based upon the current systems in place is a practical option.

During any of these rollouts, keep previous systems in place until the new one is launched and employees are fully trained. This will ensure employees do not lose access to SDSs at any point during the implementation; this avoids a sense of panic caused by change without a transition period. This being said, an official "turn off" date is recommended once training for your new system is complete.

Increasing Compliance and Reducing Costs
In conclusion, global SDS management yields far more than increased compliance and reduced costs. Its data can feed many EH&S initiatives. While a global rollout may seem daunting, it does not need to equal paperwork Armageddon because structured implementation plans and automation will ensure a smooth transition. Finally, there is no need to "reinvent the wheel." Collaborate and learn from colleagues, peer groups, and industry associations and look to third-party vendors.

This article originally appeared in the September 2012 issue of Occupational Health & Safety.