Page 56 - Occupational Health & Safety, May 2018

CHEMICAL SAFETY/SDS
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 au- thor 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, prod- ucts 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 iden- tifications 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 prod- uct 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 becom- ing big issues.
Perform Regular Inventories
Inventory each area and facility to understand what products you need to match with SDSs and associated documents. We rec- ommend performing an inventory every 12-18 months to evaluate whether any materials have been brought on site without the neces- sary documentation.
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