Page 55 - Occupational Health & Safety, May 2018

CHEMICAL SAFETY/SDS
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
www.ohsonline.com
Companies large and small have always struggled with managing Safety Data Sheets (MSDSs/SDSs) and the information about chemicals on these documents. Local, fed-
eral, and industry-specific regulations are compli- cated. Adding mergers and acquisitions, changes to products, varied regulatory agency requirements, and shifts in other identifying information further com- plicates processes, making authoring and managing SDSs a universal challenge.
The adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), al- though well intended, continues to create more com- plications for those involved in authoring and manag- ing 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 doc- uments (MSDSs) they replace.
You’re not alone. This review of SDS manage- ment 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 man- dated in 1992 at the United Nations Conference on Environment and Development (UNCED), GHS re- flects 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 at- tempts to:
■ make all systems consistent for workers han- dling hazardous chemicals
■ reduce costs to governments and companies complying with different systems
■ enable better communication of chemical in- formation
■ protect workers
■ increase international trade
UN GHS was designed in such a way that regula-
tory agencies could adopt the hazard classes, catego- ries, 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. How- ever, 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 ad- opted 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 re- vision has both amended 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 cre- ates bigger challenges to managing SDSs and chemi- cal data across the global supply chain.
Differences Emerge
The flexible global adoption of GHS has fractured the forecasted harmonization, creating unexpected out- comes. Disharmony can be found in pictograms, haz- ard phrases, and classification criteria. In the example below, you can see the differences in OSHA 2012 and EU CLP criteria:
In the MSDS to SDS conversion (to GHS) compa- nies often had to make business decisions to get docu- ments authored within the confines of the multi-year transition period. These business decisions have con- sequences for SDS management downstream.
For Manufacturers/Distributors/Suppliers
■ Authoring SDSs does not equal SDS manage- ment, 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, MAY 2018 | Occupational Health & Safety 51