What Color Are Your MSDSs?
You can leverage MSDS data and tools to create greener, safer products and workplaces.
- By Kami Blake
- Jan 01, 2011
The title of "good corporate citizen" is a coveted status that requires far more than an unblemished record of compliance. More than a decade ago, consumers started setting strong sustainability expectations through purchasing practices, compelling economic participants to shape up their environmental act. Consumer purchases, influenced by advertising and other corporate messaging, have spawned high-dollar campaigns trumpeting product safety and corporate environmental consciousness and performance. This is not likely to subside because trends clearly indicate consumers are increasingly factoring a broad base of green factors into their purchasing decisions.
Considerations that did not exist a generation or two ago now act as purchasing drivers and can easily shape perceptions of corporate entities. A steadily rising wave of consumer sentiment for safer and greener products, combined with community activism and expanding global hazardous materials regulations, gave birth to a corporate mandate, at least in theory, that those with great power have a great responsibility.
From a broad concept in the 1960s to present-day Corporate Social Responsibility (CSR) and Sustainable Responsible Business (SRB) policies, this rapid evolution has had a global impact. Built-in, self-regulating mechanisms whereby businesses monitor performance and embrace responsibility for the impact of their activities on the environment, employees, consumers, communities, and stakeholders move far beyond adherence to the letter of the law. The voluntary prioritization of public-interest issues such as impact to life and environment in corporate decision making attempts to place people and planet on an equal footing with profit.
More than a Show
Claims of corporate accountability are publicly scrutinized and require far more than well-funded, massive ad campaigns that espouse unsubstantiated or bloated assertions of environmental accomplishments. Certain minor compliance violators may be entitled to some level of forgiveness if significant effort and resources are not spared to right these past wrongs. Deceptive characters whose intent was to game the system and mislead the public may not be so lucky. The U.S.-based watchdog group Corp Watch defines greenwashing as "the phenomena of socially and environmentally destructive corporations, attempting to preserve and expand their markets or power by posing as friends of the environment."
Organizations should diligently ensure sincerity through verifiable processes and outcomes initiated on actionable intelligence, supported by tangible evidentiary fact. There is ample room on this bandwagon, but imposters may get dumped off quickly and suffer irreparable damage.
Show Me the Money?
If your organization lacks sufficient drivers to advertise, fund, or support a formidable CSR policy with strong green initiatives, it may result in a competitive disadvantage. Increasingly, bid proposal requirements request organizational CSR policy outlines, including performance measurement data. However, a pile of green bills may not be required to analyze the impact of current materials and evaluate suitable alternatives in an effort to reduce hazards that have a harmful impact on life and the environment.
Greener does not necessarily translate to more expensive, and considerations need to stretch beyond unit price. Less-regulated materials are inherently less expensive to import, export, store, transport, use, and dispose. Less-regulated and non-regulated substances often require much less in the way of documentation (MSDS, PDS, TDS, classification and labeling, chain of custody records, shipping papers, permits, disclosures, product registrations, etc.), and savings related to these costly and labor intensive activities can add up quickly.
One key is to leverage readily available information being used for a singular compliance purpose. Case in point: information found on Material Safety Data Sheets (MSDSs). As agency requirements expand and overlap and the focus of compliance programs evolves, so has the format and content of the MSDS. The addition of critical data to an existing structured document has been a simple, cost-effective approach. Today, many MSDSs offer a broad spectrum of information that exceeds OSHA requirements, including chemical classification, transportation, environmental, ecological, and disposal considerations. The value of the MSDS has shifted from fulfilling compliance for access to a required document to the immediate access of a comprehensive data set that is the starting point for much EH&S analysis and decision making.
MSDS management has gone from a tedious, unilateral exercise in pushing paper to an integral part of a company's overall EH&S strategy, impacting a broad range of activities, such as safety management, industrial hygiene, product stewardship, R&D, environmental compliance, transportation, and risk management. Data management and integration are the keys in leveraging this repository of essential information to achieve multiple compliance requirements and support green initiatives.
Three critical elements of a data-driven chemical inventory compliance program are organizational-specific information, product-level data, and regulatory content. Individually and collectively, these three components will enable lifecycle chemical management across your supply chain. Each phase of the supply chain has its own unique sustainability requirements. There is, however, a common thread throughout: access to comprehensive and accurate regulatory, substance, and product data is required during each and every phase. This is one of the most essential requirements for green and sustainability initiatives, and its importance cannot be overstated. It is absolutely critical for assessing the EH&S sustainability, toxicological, and regulatory footprint of chemical products.
Much of the data already has been collected for current compliance activities, such as hazard communication. Proper analysis will reveal how it can also be used to aid in the development and selection of safer and more environmentally friendly products. The well known risk evaluation method Risk = f(hazard*exposure) is useful when determining the relative desirability of products and substances. The hazard variable is exactly the kind of intelligence you are likely to find among toxicity and classification data already collected for compliance activities.
To understand how data found on MSDSs and in your MSDS management system can be leveraged to create greener and safer products and workplaces, first conduct a comprehensive review and outline of compliance programs and pending corporate initiatives. We recommend starting with an examination of your current data set, processes, compliance history, waste stream, and the determination of your greatest current impacts and risks.
Evaluate measures such as severity and potency. Consider specific hazards that are most feasibly reduced and/or eliminated. A detailed analysis will provide a wealth of information regarding environmental effects, disposal considerations, risks to human health, and exposure data.
Next, understand the current and pending regulatory landscape. Some components and products may have restrictions in global marketplaces that might be a significant source of your company's revenue. This type of information should already be something your company is maintaining in its Regulatory Affairs departments. Next steps include a collaborative effort with a highly qualified and strongly trusted data provider to understand the regulatory concerns that may be pending. For example, is EPA working toward a ban on a particular Chemical Action Plan under TSCA that will affect one or more of your options? Has one or more of your substances been listed as a SVHC under REACH?
Creating Your Green Toolbox
Once you understand which criteria matter most and the related profiles of your substances and products, as well as the associated global regulatory restrictions and limitations, you can create normalized ratings in order to compare substances and products across use types. Robust tools are available for developing ratings that enable green purchasing decisions and product formulations based on acceptable hazard ratings for components that are appropriate to the required use scheme.
What exactly should companies look for when evaluating existing data or researching possible outsourced data alternatives? If the goal is evaluating data for green or sustainability initiatives, users will need access to chemical profiles and substance data for comparison and analysis of product toxicity, environmental impact, use type, and cost. Consider choosing a data source that leverages global CAS level profiles and chemical classification information. Examine and compare available solutions and view the results from a customer, liability, and sustainability perspective. If your competitors' products gain better ratings based on your analysis, how can you improve? If yours are better, let your customers know!
The preferable solution ideally calls for utilizing a flexible platform with predetermined or default criteria to calculate ratings and group products into categories. It may even include material costs to create direct and meaningful comparisons. While green procurement and product evaluation are important to companies, without a universally accepted standard for sustainability, it can be difficult to develop and implement a successful green program. The right tool can provide a baseline scoring methodology that can be customized to suit the requirements of a specific company or industry.
Tools must be flexible and intelligent, providing guidance to those who might still be defining their parameters. In addition, the system should integrate seamlessly with enterprise chemical and regulatory data in a way that enables decision makers to quickly assess the sustainability footprint of raw materials or finished goods, compare products to evaluate more environmentally friendly alternatives, and create a simple baseline methodology to measure improvement.
Safer and More Sustainable Choices
Timely access to the right EH&S data and tools can support compliance and sustainability initiatives throughout the enterprise, product life cycle, and supply chain. Ensuring that materials consumed and produced conform to corporate and regulatory mandates can create safer workplaces, reduce toxic footprints, and facilitate the development of greener, more environmentally friendly products. As if that isn't enough, you may be surprised to find a little extra green added to your bottom line.
This article originally appeared in the January 2011 issue of Occupational Health & Safety.
Kami Blake is a Solutions Engineer with 3E Company. In this role, she provides technical expertise to assess regulatory requirements, information management technology, and analysis of existing hazmat programs to develop compliance solutions. Blake launched her career in 1982 in the United States Marine Corps and is a two-time Navy Achievement Medal recipient for small systems implementation and training. Prior to joining 3E in 2002, she served in Quality Assurance, Supply Chain Management and Process Engineering roles in the biotech and medical device manufacturing industries.
She can be reached at [email protected] or 800-360-3220.