MSDS authors, corporate toxicologists, industrial hygienists, and environmental health and safety professionals, take heed: According to OSHA estimates, nearly 1 million Material Safety Data Sheets will have to be re-authored or updated once the new provisions of the Globally Harmonized System (GHS) take effect in the United States. Specifically, according to OSHA research1, the baseline facts of the Hazard Communication environment are:
- 880,000 hazardous chemicals are used in U.S. workplaces alone
- 5,000,000 workplaces contain chemicals on site
- 40,000,000 workers are affected by the provisions of the Hazard Communication standard (HCS)
So the elephant in the room is, 'How are organizations going to efficiently update and distribute nearly 1 million revised safety data sheets to 40 million workers, all in a cost-efficient manner?' Leaving the safety data sheet authoring challenges aside for now, let's focus on the avalanche of documents that is going to bury chemical producers and chemical end users alike in Material Safety Data Sheets (MSDSs) and chemical data.
Communication Requirements for Chemical Manufacturers
In the United States2, the manufacturer maintains primary responsibility for disseminating updated chemical information to the chemical end consumer. Chemical manufacturers must ensure appropriate and current material safety data sheets are shared with distributors and employers (chemical end users) with their initial product shipment and any time an MSDS is updated.
Additionally, suppliers should respond to 'new and significant' information they receive about a chemical hazard by updating the label and safety data sheet for that chemical. New and significant information is any information that changes the GHS classification of the substance or mixture and leads to a resulting change in the information provided on the label or any information concerning the chemical and appropriate control measures that may affect the MSDS. This could include, for example, new information on the potential adverse chronic health effects of exposure as a result of recently published documentation or test results, even if a change in classification may not yet be triggered. Updating should be carried out promptly -- in fact, in the United States, chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical must revise the MSDS and labels for the chemical within three months of becoming aware of the new information.
Suppliers also should periodically review the information on which the label and safety data sheet for a substance or mixture are based, even if no new and significant information has been provided to them in respect of that substance or mixture. For example, this may require a search of chemical hazard content databases for new information.
Impact of GHS
The Globally Harmonized System will have a significant impact on hazard communication upon OSHA's final adoption of its provisions. The current expectation is there will be a three-year transition period for organizations to adopt the provisions of GHS, including updating safety data sheets and chemical labels, circulating revised chemical safety documents, and training employees on the changes.
The impact to organizations, especially those manufacturing chemicals, is that without efficient processes and business automation, the new requirements will be a compliance burden for many businesses. Similar to unshoveled snow in the middle of a New England winter, the avalanche of updated MSDSs and customer requests for updated MSDSs will bury the unprepared.
The Need for Automating MSDS Distribution
One way to shovel yourself out is to utilize MSDS Distribution technology and services. MSDS Distribution solutions employ business rules for circulating new MSDSs in an existing network for sharing and communicating chemical safety data sheets. Think of it as the digital version of a pack and ship process for hazard communication mailings whereby outgoing messages are automatically triggered based on your business rules, the organization's product shipments, changes in safety data sheets, and your customers' preferences.
Considerations for Streamlining MSDS Distribution
1. Push or Pull. The provisions of OSHA's current Hazard Communication Standard (HCS) maintain it is the chemical supplier's responsibility to supply the required chemical data information in the form of MSDSs and chemical labels to employers. Second, it is the employer's responsibility to provide readily available access to such information to affected employees. Therefore, chemical suppliers must be able to efficiently 'push' new and updated chemical safety documents to employers and also support the occasional ad hoc request ('pull') by customers or other end users. It's useful to support both methods, but the main emphasis should be on the right outbound push mechanism and process.