The recent OSHA announcement proposing to align the current Hazard Communication Standard in the United States with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) triggered a flurry of discussion regarding the worldwide impact of GHS standards. GHS will have profound effects on the chemical data management industry, both for companies that must author and publish safety data sheets (SDS) for their chemical products, as well as those companies that must manage SDS and related chemical information for onsite chemical inventories.
Specifically, the proposed regulatory updates will require revisions in both content and format of current safety data sheets, thus causing an “authoring avalanche” for the millions of SDS documents currently in circulation. Furthermore, companies will have to choose whether to create multiple regional or even country-specific documents or one globally compliant document to comply with the globally facing GHS standard.
COMPLIANCE GOULASH
Historically, OSHA and other safety regulatory bodies created standards that utilize a performance-based approach. That is, the agencies outlined the expected requirements, but left room for interpretation to companies in the actual implementation of health and safety measures. Furthermore, each region and, many times, each country, established unique requirements and approaches for hazard communication.
Therefore, companies are left with a “goulash” of international and national hazcom requirements that varied based on the type of goods being produced, where those goods were being shipped and the requirements and local regulations of the customers they were being shipped to. It is easy to extrapolate the consequences of this environment: 1) non-uniform communication, training and understanding for employees (the very resource that the standards were trying to protect), 2) varying degrees of hazard communication safety implementation and 3) an extremely high cost of compliance for the companies producing, processing or distributing products involving chemical components.
Consequently, a number of countries, including the United States, as well as international organizations and stakeholders, participated in developing the GHS to address inconsistencies in hazard classification and communications. GHS was developed to provide a single, harmonized system to classify chemicals, labels and SDS with the primary benefit of increasing the quality and consistency of information provided to workers, employers and chemical users. It affects:
- Classification of the hazards of chemicals according to the GHS criteria.
- Communication of the hazards and precautionary information using safety data sheets and labels.
The benefits will include greater consistency with a clear message across sectors through harmonization of signal words, pictograms and hazard warnings; better workplace protection; and the cost reduction associated with preparation of labels and (material) safety data sheets by classifying chemicals once, for all agencies. Internationally, GHS will enhance protection of people and the environment, facilitate international trade in chemicals, reduce the need for duplicate testing and evaluation and assist countries and international organizations in the sound management of chemicals.
AUTHORING AVALANCHE
Although it appears not all countries, or even agencies within a country, agree completely on how GHS should be applied, there are a few areas related to material safety data sheets (MSDS) and labels that most have come to agree on.
First, MSDS, soon to be simply known as safety data sheets (SDS), will extensively change after adoption of GHS, as all products will need to be classified for health and physical hazards based on GHS criteria. Additionally, the flexibility of format will be removed. Specifically, the 16-section document (as adopted by ANSI Z400.1-2004) will be required. The order of the 16 sections will be specified, with section two prescribed for hazard identification and section three defined for components. The consistent format greatly will assist employees in quickly and easily finding pertinent information on the SDS.
What this means to industrial hygienists, corporate toxicologists and others responsible for the communication of hazardous chemical components is that an authoring avalanche is about to hit as the millions of MSDS currently in circulation have to be revised, re-written and re-published to comply with the GHS provisions. There may be a 3- to 5-year window in which to bring all SDS up to par, but businesses and corporate hygienist and safety professionals still have a daunting task in front of them to meet the requirements.
Bear in mind that this is not “the sky is falling” rhetoric. The United Nations published and approved the first edition of GHS in 2003. The European Union already has adopted GHS, as has Japan and China. Other countries, such as Canada, are, like the United States, currently working on aligning their current regulations with GHS.
TWO APPROACHES
Now that most insiders agree that the question is “when” and not just “if,” IH professionals responsible for MSDS authoring must determine the best approach to complying with GHS. Despite the global nature of the GHS framework, individual countries still will have latitude on how certain aspects of GHS are implemented. The result is that companies still will need to produce regionally relevant SDS documents, regardless of whether they are in global form or in a country-specific format.
One approach is to continue to produce country, agency or regionally specific documents that meet the requirements of each region or area in which a company does business. North America, Europe and Asia Pacific, as well as OSHA, WHMIS and EU, all prescribe certain methods for communicating material hazards. This has been the historical approach to MSDS authoring and still is prevalent today. Not only do separate documents need to be prepared to meet each country's specific regulations, but multiple documents for multiple languages also must be prepared. Given the massive SDS re-write effort that GHS imposes, the burden of this approach is obvious.
A second approach that is gaining support in light of GHS's global focus is a method geared toward producing a globally compliant SDS document that also meets the provisions of applicable regional requirements. The advent of more flexible SDS authoring software enables organizations to classify material hazards according to global and regional standards once, while creating multiple SDS versions simultaneously that meet each region's requirements. The authoring software utilizes pre-populated phrase libraries and a multi-agency hazard classification rules engine that separates the classification process from the output process. This allows companies to either produce one, globally compliant document that spans the needs of all applicable regions or multiple documents driven from one, globally driven set of rules.
The operational advantages of this streamlined approach are clear in that organizations now can take advantage of the “stored intelligence” of the SDS authoring system to produce globally and/or regionally at the touch of a button, rather than having to re-author multiple documents for multiple agencies. The business advantages of this approach include more efficient, cost-effective SDS authoring; reduced barriers to trade; and more cost-efficient government regulation.
THE GOAL
The goal of the GHS standard is to create consistency and harmonization of chemical safety documents and hazard communication. Organizations that both author and manage safety data sheets will be impacted, with an exceptional effort required for companies that must author, or re-author, safety data sheets to meet the new global standards. Therefore, utilizing an SDS authoring system or safety data sheet services provider that can provide standardization of the inputs, while allowing flexibility of the output, will create a competitive advantage for companies dealing with the looming authoring avalanche.
International and domestic EHS officials advocate that the new provisions will make compliance, training and user comprehension easier. However, companies must take a smart approach to adoption that doesn't overwhelm their own resources. Taking this one step further, companies that employ a global approach to SDS authoring will reap the benefits of a unified approach to preparing and presenting chemical information including timeliness to market, cost effectiveness and consistency of information for end users.
Ruth Mayo is a regulatory compliance specialist at SiteHawk. She has 6 years of industry-related expertise in regulations, chemical information management and training. Ruth can be reached at [email protected].