With just a few short months until the next GHS deadline arrives, there are still a lot of misconceptions surrounding the final rule provisions. Many chemical manufacturers are still evaluating tools and processes for making the necessary hazard classification updates by June 1, 2015. Others have started re-authoring MSDSs and SDSs in a piecemeal fashion, only to find the project is more labor intensive and complex than they anticipated.
Wherever you are in the GHS transition process, the following misconceptions are worth reading and correcting today.
The GHS Transition Is Simply a Formatting Exercise
Given all the official jargon you’ve read about the GHS, it’s easy to confuse like-sounding terms — for example, “reclassify” and “reformat.” But these are actually two distinct and separate activities. When it comes to chemicals, companies need to do both.
In other words, for any chemicals that you produce (manufacture, process, formulate, blend, extract, generate, emit, or repackage), you must:
a.) reclassify those chemicals according to new classification criteria, and
b.) reformat your chemical labels and safety data sheets to reflect those changes.
If you haven’t started the reclassification process yet, you may already be months behind your competitors. Your downstream customers may be waiting for your material SDSs to inform their own. And you may lose business as a result.
Classifying Chemicals Is a Judgment Call
Some chemical specialists will remember how the process of chemical hazard evaluation worked before today’s GHS alignment. And the informality of that process — which included less involved, sometimes subjective designations — may be clouding their perception of what’s needed in the current environment. But the truth is, the GHS provides very specific guidance (via its Purple Book) on what constitutes a hazard and how a chemical should be classified.
Companies now need to map out the exact chemical makeup of all potentially hazardous materials and chemical mixtures. Materials must then be analyzed based on individual components — accounting for toxicity, reactivity, and the overall class and category of each chemical part. In many cases, this process will involve lab testing and/or research into scientific archives, like the EPA’s chemical database.
GHS also applies an “additivity principle” in which you must base hazard classifications on each individual chemical component and on groups of components that share common hazard potential. Individually, your chemicals may not require a specific categorization, but combined they may.
Some companies will even discover that seemingly benign materials they’ve worked with for years now require safety data sheets and chemical labels.
There Are Ready-Made Templates to Follow
Between the GHS Purple Book and the numerous SDS examples that are available to your experts, you may think much of the groundwork has already been done for you. But this could be another costly misconception — both in terms of time lost tracking down answers, and more importantly, in terms of your teams’ safety.
As a material commonly used in chemical manufacturing, sulfur gives a great example of why single-source chemical referencing is insufficient. Because if you went by the Classification Labeling and Packaging (CLP) regulation alone, you would think sulfur should be classified as Skin Corrosion/Irritation, Category 2. But after further investigation, you would find that sulfur should also be classified under Acute Toxicity Inhalation, Category 4; Acute Toxicity Dermal, Category 5; and Acute Toxicity Oral, Category 5 — all in addition to its CLP classification. Additionally, the Sigma-Aldrich safety data sheet for sulfur indicates that sulfur is classified as a Flammable Solid, Category 2. But this categorization is not specified under the CLP.
So how much research is best practice? When authoring your SDSs and chemical labels, a good rule of thumb is to use three to five reliable sources (per chemical) for chemical determinations, chemical testing data, and regulatory body finds. By cross-referencing multiple toxicological databases, you will likely uncover additional hazard classifications for the chemicals and components you produce. Incorporating these into your safety data will help to protect your workforce, while ensuring your suppliers and distributors have the most comprehensive information available.
If a Hazard Isn’t Outlined by the GHS, We Can Skip It
Some hazards are not classified under GHS, but that doesn’t mean they can be ignored. For example, simple asphyxiants and combustible dusts do not have any specific GHS pictograms associated with them, and yet it’s crucial that they be documented with proper warnings. In the first case, your SDS hazard statement should include language like, “May displace oxygen and cause rapid suffocation.” In the second case, your hazard statement should explain, “May form combustible dust concentrations in the air.”
There’s also an entire category of materials that don’t neatly conform to GHS frameworks. The hazards they pose are termed “Hazard Not Classified by the GHS” or HNOC. These hazards must be documented in Section 2 of your SDS and/or listed under “Supplemental Information.”
The Entire GHS Transition Shouldn’t Take More than a Month
It’s difficult to estimate how long the GHS transition will take for different companies. The chief variables include the number of chemical materials you produce, and the complexity of those materials/mixtures. How many raw materials are you using? And which families of chemicals are involved?
Your GHS timeline also depends on how you choose to classify your chemicals and subsequently author your data sheets and labels. Technically speaking, you can do the work manually, but that will mean individually entering any data you receive from vendors and suppliers. It will also mean keeping track of all revisions and iterations as you cross reference different databases. And in the long-run, a bulky manual strategy may eat up significantly more time and budget, especially if it needs to be handed over to a new employee, or your company gets audited.
If you opt to employ an automated SDS management solution, you may be able to manage the one-month timeline. You’ll also ensure greater accuracy. Some SDS authoring and management solutions are even built to allow chemical composition data within certain thresholds, so your safety data is complete and compliant without revealing valuable proprietary information.
Gary Vegh co-founded ERA Environmental Management Solutions in 1995. Today he is the company’s senior toxicologist and a compliance expert with over twenty years of experience educating environmental professionals and working closely with regulatory agencies and manufacturers. ERA provides environmental management software to some of the world’s leading manufacturers, including Volkswagen, Moog, BMW, Nalco, Medtronics and Nissan.