The Disharmony of SDS Management: The Real Business Impact

The Globally Harmonized System for Classification and Labeling of Chemicals isn't actually that harmonized. This disharmony creates bigger challenges to managing SDSs and chemical data across the global supply chain.

• By David Williams
• May 01, 2018

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 Labeling 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 was the real business impact? 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.

An increase in product impact awareness coupled with a non-standard global regulatory landscape yielded the need for a harmonized regulatory system. 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) and mandated in 1992 at the United Nations Conference on Environment and Development (UNCED), GHS reflects existing systems (U.S., E.U., Canadian, and U.N. TDG) and the most recent version of the legislation—the seventh revision¹—was released in 2017. GHS attempts to:

• 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

UN 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. For regions with less mature or non-existent regulatory frameworks, GHS offers a blueprint for success. However, there are some important differences between GHS and the regulations put into place by agencies that incorporated the system.

GHS is not mandatory. Until GHS criteria are adopted by a regulatory body (OSHA, CCOHS, etc.) there is no binding obligation to use the criteria.

GHS is not complete. 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 not static. 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.

GHS is not harmonized. The Globally Harmonized System for Classification and Labeling of Chemicals isn’t actually that harmonized. This disharmony creates bigger challenges to managing SDSs and chemical data across the global supply chain.

Differences Emerge
The flexible global adoption of GHS has fractured the forecasted harmonization, creating unexpected outcomes. Disharmony can be found in pictograms, hazard phrases, and classification criteria.

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.

For 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, such as paint in multiple colors, business combined multiple SDSs into one SDS.
• 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.
• Businesses changed the method or the software used to author SDSs and, in some cases, there are missing product codes or the data weren’t migrated in time.
• In other cases, because of criteria and classifications, products that might have been on a single SDS were split into multiple, and similar materials appear on the same SDS.

For Employers

• Multiple MSDSs become one. No matter whether 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 one 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.
• There are 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.

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 actively managing SDSs.

Although there isn't a cure for the complications related to GHS yet, below is a recommended therapy plan for driving compliance:

Annual Checkups
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. We recommend performing an inventory every 12-18 months to evaluate whether 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 an SDS.

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

• Web search
• Manufacturer website
• Contacting the manufacturer by phone or email

When requesting an 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

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 an 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 on site 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:

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

2. What products (product codes) does this SDS cover?

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

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

5. 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.

Leveraging these tips, you can mitigate GHS challenges, educate your workers, and provide safe and compliant workplaces to protect your employees, products, and surrounding communities.

Reference
1. https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev07/English/ST_SG_AC10_30_Rev7e.pdf

This article originally appeared in the May 2018 issue of Occupational Health & Safety.