HazCom Compliance: A critical component of a comprehensive SH&E compliance program

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Courtesy of 3E Company

Hazard Communication Standard (HCS) compliance has evolved significantly as:

- it has become a part of a broader SH&E and supply chain compliance, effort;
- the MSDS has evolved into a clearinghouse document for rege-lated material data that exceeds the scope of workplace safety;
- technology has progressed rapid¬ly, providing automated solutions to collect, access, store, refresh (update), analyze, aggregate, integrate and... transfer critical SH&E information;
- data management and records retention has stretched across the entire product life cycle.

Expanding global requirements, when combined with an increasing public demand for ecological and envi¬ronmental performance, have created a comprehensive data demand for haz-ardous substances. Examples of these expanding global requirements include UN's Globally Harmonized System of Classification and Labelling of Chemi¬cals (GHS); Europe's Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (REACH); regulatory agency reforms including EPA's reform of the Toxic Substances Control Act (TSCA); increased enforce¬ment from EPA, OSHA and Depart-ment of Homeland Security (DHS); and proposed rules by Pipeline and Hazardous Materials Safely Adminis¬tration (PHMSA). The need for a broad spectrum of readily accessible data is driving the development of global compliance tools supported by compre¬hensive, complex data repositories.

Fortunately more than 30 years ago, HCS created a vehicle to warehouse and distribute vital product- and sub¬stance-level hazard information. Today, the MSDS is the initial data source for key product and material metadata. What once existed as a stand-alone workplace safety compliance require¬ment has evolved into the cornerstone of a comprehensive SH&E compliance program.

SH&E & Supply Chain Compliance Efforts

Better business decisions are based on quality data, which begins with an accurate chemical inventory. Com¬plete inventory lists account for pure substances, mixtures, intermediates, regulated byproducts and use chemi¬cals. Cradle to grave, supply chain tracking has led to a life cycle chemical management approach. ,

This methodology is becoming wide¬ly accepted as an industry best practice. It defragments the operational disci¬plines and requirements of research and development (R&D), manufactur¬ing, transport, use and disposal. What were once separate silos of expertise, technology, data and applicable regula¬tions now can be effectively integrated into a single managed system.

Life cycle chemical management in¬tegrates three equally important pillars of information.

  1. Organizational data is gener¬ally company and facility specific. It includes site inventory lists, line item quantity and usage data, and custom product information unique to an organization or location (e.g., internal item numbers, SAP material identifier, waste codes).
  2. Product- and substance-level data are a combination of metadata indexed directly from MSDS and classified data (chemical, transportation and waste) that are derived from MSDS informa¬tion and regulatory analysis.
  3. Regulatory content consists of chemical abstracts service registration number specific lists that identify regu¬lated substances, key data elements and parameters (e.g., exposure limits, de minimis quantities, reporting thresh¬olds, carcinogenic, mutagenic, toxic to reproduction identification), reporting agency information, and foil or abbrevi¬ated regulatory textual references. The breadth of global chemical regulation can be overwhelming.

The value of MSDS has broadened ambitiously beyond a document re¬quired to comply with right-to-know laws. Beyond the value of the hard copy document itself, the content value is immeasurable. Consequently, MSDS management programs have transformed into chemical inventory management and compliance sys¬tems. These integrated solutions bring together organizational information, product- and substance-level data along with regulatory content to quickly identify regulated materials and the ap¬plication of regulatory requirements.

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