Can GHS Be a DIY Project?

We can all agree that the Globally Harmonized System (GHS) does not go as far in terms of harmonization as we might have hoped. Don’t get me wrong; I will take any number of differences in country GHS implementations over the completely different regulatory schemes we had to deal with previously. However, it is human nature to try to continuously improve and determine more efficient ways to cope with the issues we face.

Do you watch any of those Do It Yourself (DIY) shows on TV or spend time scrolling through Pinterest to see all the amazingly creative things people are building? I’ll admit that I spend more time doing this than I probably should! I love the idea of DIY because it allows you take something like a piece of furniture –such as a dining room table – and turn it into something else, like two console tables.

DIY solutions are great because what you build/create can be done to your exact specifications. It will fit the need that you have as opposed to being forced into the size or color contained in your local big box store. It also allows you to look at what you already have and reuse it in a new and better way.

How are GHS and DIY Related?

You may be asking yourself how DIY is related to GHS, and that would be a very good question! The GHS itself was built with DIY in mind. A specific country can pick from a set of building blocks, customizing the hazard classifications implemented as well as the severity of the hazards. In other cases, countries can decide at what cut-off an individual component will cause the overall mixture to be classified. In more complex cases, countries have implemented entirely new building blocks or other requirements.

This flexibility allowed a good portion of the world to agree on a single standard, while also keeping the same levels of protection in place for countries with existing hazard communication programs. However, it also opened Pandora’s Box. Countries that previously did not have systems in place now have formal hazard communication programs, and like those countries that had existing systems, they implemented the building blocks in a way that fit their country’s requirements.

This creates a bit of a dilemma for businesses. Prior to GHS, if a country did not have a formal hazard communication regulation enforced, a common pragmatic approach was to send a translated EU dangerous substances directive (DSD) or dangerous products directive (DPD) safety data sheet (SDS) or U.S. OSHA material safety data sheet (MSDS). Now, as countries implement their own hazard communication system, it does not feel appropriate to just send a translated sheet.

While multiple countries were implementing their own versions of the GHS, companies were trying to figure out how to do more with less. Resources are tight and keeping up with rapidly changing regulations while also updating and authoring sheets for new products can be very demanding.

So now we’ve seen that countries have implemented their own DIY standards using the Purple Book as the backbone. The next question is whether businesses can use this same DIY approach when fulfilling the requirements of those standards. I think that if we take a more pragmatic view of the regulations, take inventory of what countries are requiring around the globe and understand what hazard classifications our materials fall into, we can do it!

Taking the DIY Approach

In the pre-GHS world when I was authoring, we would have some regional SDSs/MSDSs. They might be for North America or Asia Pacific. In the GHS world, I don’t think region matters as much as the implementation itself does. For example, it is common for countries to not implement building blocks such as Acute Toxicity – Category 5 and Skin Corrosion/Irritation – Category 3. If we look at the country implementations and group countries which have implemented similar building blocks, we might see a South American country that closely resembles the implementation of an Asian country and efficiencies could be created by authoring a single sheet for multiple countries. Now, I am not saying that the exact same sheet will be sent to both areas. It certainly is the case that the addresses, emergency phone numbers, etc., will need to change, but much of the SDS will be consistent.

On top of looking at the implementation of the different countries, it also is a good idea to take inventory of the hazards classifications that your products fall into. For example, in looking at the U.S. implementation, if your materials are not classified as simple asphyxiants, combustible dusts or pyrophoric gases, then the OSHA implementation takes on a more purple hue. There is a lot of emphasis in the United States on hazards not otherwise classified, but this idea in not a new concept. The Purple Book has always addressed this, although using the more cumbersome term of “other hazards that do not result in classification.” If your material has a hazard that is not covered by the GHS, it is important, and expected, to communicate this information in all other countries.

Once you understand the different country implementations and the hazard classifications your materials fall into, it could be possible to implement a more pragmatic approach to compliance. For example, three countries have similar implementations, but one of them implemented Acute Toxicity – Category 5. There are a couple of different options that could be taken depending on how you author SDSs. These include:

Allowing the Category 5 classification to show for all three countries. This could be a competitive disadvantage, but it is possible that the efficiencies of using one SDS for multiple countries could outweigh the risk.

Evaluating your products to see how many have a Category 5 classification. If there are very few, then it is possible that these could be managed separately and that for most of your products a single SDS could be used. This will allow you to issue more specific SDSs while still better managing the workload.

Issuing SDSs with additional hazards shown can be a good thing or a bad thing depending on your perspective. Issuing an SDS with environmental hazards, when they are not required, is a way of showing that your company is dedicated to protecting the environment and is going above and beyond a country’s requirements.

Let’s look at an example of how this might work and compare the building blocks and cut-off levels implemented for the United States and China:

Differences in Building Blocks:

In terms of the cut-off levels for carcinogens, reproductive toxicity, sensitizers and specific target organ toxicities, OSHA implemented the lowest level available. For example, Carcinogen – Category 2 has a classification cut-off of 0.1 percent.  On the other hand, China did not define the cut-off levels to use. In terms of classification, they have a straight Purple Book implementation.

So, what do we have? For classifications, we must first determine whether any of our products have these classifications. If they don’t, the decisions are easy. If they do, we need to decide whether we continue to author sheets separately or whether we make some pragmatic decisions. The decisions also may hinge on which classifications are applicable. The additional OSHA hazards will make everything more difficult, but an Acute Toxicity – Category 5 might not be a big deal. Especially as data in this range should be included in any mixture classification calculations for the United States.

Depending on your perspective, the decision on cut-off levels could be very easy or become a deal breaker. We know that we must use the lower levels in the United States; anything other than that would create a compliance issue. Where we have some room is in China, where a decision was not made. As there is no official requirement, competitors may stick with the higher limits to make their products look less hazardous. This may compel you to stick with these higher levels as well, which makes a generic sheet impossible, unless these hazards are not applicable. On the other hand, if you are willing to be open in explaining that you are using the lower limits, those who understand SDS classification will likely understand why your SDS looks as if it is more hazardous.

Whether you take a more pragmatic approach or not is a question that you will need to ask yourself, but as more and more countries implement GHS and resources continue to be tight, it is a reasonable one to ask. There are creative solutions out there, the trick is to think about how they can be applied to your situation.

Finally, creating generic SDSs will be dependent on your authoring process. Do you have a process which allows you to be flexible in creating your own rules/forms, or are you using a software system with a very rigid structure? You will need to take a close look at what you are currently doing and see how you might be able to manipulate it. If your current process does not allow you to implement more efficient processes, then a change may be in order. In the end, you need to understand what your requirements are, where you might be able to combine SDSs to create efficiencies and what pragmatic approaches you are willing to take.

If you could create your own GHS implementations, how would you design them?