Effective, compliant, and up-to-date hazard communication documents, especially Safety Data Sheets (SDSs), are a global requirement and a critical centerpiece for effective product stewardship practices throughout the product life cycle. Unfortunately, tracking international chemical regulatory guidelines and providing accurate and compliant hazard communication has never been more complex.
The Regulatory Landscape
Authoring accurate, compliant SDSs has always been a mission-critical obligation. But the European Union's Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) legislation and the United Nations' Globally Harmonized System of Classification and Labeling (GHS) have brought new challenges to this already demanding task.
For example, for higher-volume hazardous substances, REACH requires companies to attach an 'exposure scenario' to the SDS, The exposure scenario describes how the chemical can be used in a safe manner, with minimal risk, for the intended use, and can cover each individual substance in the chemical or the mixture as a whole.
GHS also has profound implications for compliance professionals and requires extensive planning and preparation. In particular, managing the classification requirements of OSHA's Hazcom 2012 revision, which aligns the Hazard Communication Standard with GHS, is particularly challenging. To conform to these requirements, manufacturers and importers need to reclassify their hazardous materials and capture additional data for publication on labels and SDSs. New criteria for classifying human health and physical hazards, as well as OSHA's new 'hazards not otherwise classified' (HNOC) category, have far-reaching implications for SDSs and product labels. In many instances, SDSs and shipping labels will need to be re-authored to comply with the new guidelines set forth in Hazcom 2012.