« The UNs’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has had a tremendous impact on industry and a profound effect on safety and compliance initiatives around the globe. With many countries adopting and implementing customised versions of the system, true harmonisation is becoming increasingly unlikely.
To ensure conformance with this wide-ranging and evolving initiative, it is important to take a full life cycle approach to compliance activities, as each phase has different requirements and obligations.
Downstream users have obligations to train their employees on the changes to the standard, but they also need to ensure they are able to receive updated safety data sheets (SDSs). They also need to track if documents have changed, and if so, analyse which data on the document is different from the earlier version. Proper workplace training is also an important consideration.
Upstream suppliers and manufacturers need to re-evaluate how their substances and mixtures are classified for each regulatory entity, country and/or region and frequently need to re-issue SDSs and labels.
To illustrate the wide-reaching impact of GHS, a snapshot of three companies in different industries is offered, with their unique perspectives on addressing parts of their respective GHS obligations.
Forest products company
A large forest products company was struggling to meet GHS’s required changes in a timely manner.
The company has a robust SDS programme in place, leveraging a platform to help manage its SDS library and ensure compliance with regulations at the national level in several countries around the globe.
The company’s expansive GHS programme encompasses the following initiatives:
• obtaining GHS-compliant SDSs from its suppliers;
• extracting and indexing GHS information from the SDS;
• producing GHS labels for secondary containers;
• GHS classification and labelling reports, showing which SDSs in its inventory have been updated;
• GHS regulatory reporting, showing which products have Cas numbers on GHS regulatory lists; and
• revision alerts, notifying when suppliers have provided a new GHS-compliant SDS for products in its inventory.
Although GHS remains the company’s biggest environmental, health and safety (EHS) compliance challenge, implementing such a comprehensive programme helps ensure conformance by making GHS-compliant SDSs from its manufacturers readily available to employees.
The company has also been able to leverage the outputs of its GHS efforts to support additional EHS compliance activities, such as streamlined development of compliant container labelling and improved chemical inventory management. They also benefited from an improved reporting process that made it easier to gather and analyse chemical and product data from its inventory.
Specialty chemicals manufacturer
GHS compliance is a challenge faced by companies in a wide range of industries.
In the case of a global specialty chemical manufacturer, the struggle to provide GHS-compliant safety data sheets (SDSs) and labels, in each of its markets, was a growing concern. With a product line that includes over 500 unique products, and each product can contain up to 30 substances, authoring became a very time consuming and often frustrating process.
Developing each document was a very manual process – every SDS had to be developed individually, and the mixture Rule calculations did not consistently provide the outputs that were desperately needed.
The manufacturer, which ships to approximately 70 countries, opted to augment its efforts by deploying an authoring platform to assist in the development of comprehensive and accurate SDSs and labels with the classification, rules logic and template layouts required by each country and region.
Such an approach helped the company address its biggest challenge in conforming with GHS – authoring documents in multiple country formats and languages, combined with an often aggressive timeframe for document development. It has also enabled significant improvements in efficiency and accuracy.
Oil and gas company
This global oil and gas company has faced many challenges in its quest to achieve environmental regulatory compliance in the context of constantly changing international regulatory initiatives.
The company was burdened with identifying, tracking, maintaining and complying with international regulatory guidelines to protect the health and safety of employees and consumers, as well as the environment.
Recently, compliance with the EU’s REACH and all of the national implementations of GHS has been an especially time-consuming task.
In particular, keeping up with GHS’ implementation around the world has been a difficult challenge. The company’s regulatory team is constantly working to stay on top of who is doing what, and what is happening where. However, they’ve found it increasingly hard to plan ahead and design systems to meet regulatory requirements that are a moving target.
Challenges resulting from changing regulatory initiatives have also impacted the company’s ability to efficiently and effectively produce and maintain SDSs, labels and other hazard communication documents for its products.
To overcome these challenges, the company chose to integrate global regulatory chemical content into its existing product lifecycle management (PLM) system, used for compliance related activities, in order to optimise the authoring of GHS and otherwise compliant SDSs. In addition, when the volume of authoring becomes too burdensome for the company’s in-house team to manage, it has outsourced components of its programme to increase efficiency. The outsourced services are performed directly on the company’s existing IT infrastructure, ensuring all activities are contained in a centralised system.
The company also stays abreast of regulatory changes by using an online chemical regulatory compliance reference tool. Such an approach helps support decisions, related to a variety of business issues that must be considered when manufacturing products, such as:
• making sure SDSs are compliant within the markets in which the products are sold;
• making sure labels are acceptable in the destination market;
• identifying regulatory authorities, which require notification when exporting;
• knowing which agencies have to be notified in the event of a chemical release or spill; and
• ensuring products can be sold in the intended markets.”
Article by Matthew Johnston, Global Vice President of Business Development, 3E Company
Cet article n’engage que son auteur/ This article is the sole responsibility of the author