Hazard Communication Standard by ICSDS.Com Helps Employers Assure Better Safety at Workplaces

OSHA introduced GHS into its Hazard Communication Standard in 2012 with the objective of assuring that employees and employers are better informed about the nature of chemicals they handle. MSDS need to be updated to the GHS SDS formats. This could be perceived as a chore but, in the end, it leads to uniformity and easy communication. The result is reduced injuries and risks at workplaces.

The accent is on employee training that will improve hazard communication and make them informed so as to read, interpret and understand data sheets as well as safety labels. Employers benefit by applying safety leadership methods such as a plan to reduce accidents at workplaces and motivate employees to take to the new system; support the change and engage staff in the program; ensure employees become proficient and be proactive in adjusting methods to the new hazard communication standards.

Helping employers achieve their objective is the hazard communication standards by icsds.com effort. MSDS need to be updated to SDS or entirely new SDS and labels need to be developed should a chemical have been reclassified. Data sheets need to be prepared in the 16 section format that gives out vital safety information while safeguarding trade secrets. 

At the same time emphasis is placed on preparing labels the right way with the right choice of symbols and warning words that give precise information at a glance. This part is supported by professional training conducted in-house by experts of ICSDS to ensure all employees who are connected in some way or the other with the hazardous chemicals become thoroughly familiar with the data sheets and labels.  This is necessary because the old data sheets focused on hazard definitions that were not detailed. The new HazCom goes into more details about physical, health and environmental hazards with specifics on severity of impacts of the chemicals according to their classification and sub-classification.

The changes may also call for testing based on hazard assessment in which case too ICSDS proves helpful with its professional team of knowledgeable experts providing assistance to help manufacturers do it right and comply with regulations while taking care of safety of employees. This goes hand in hand with product composition reviews and assessment of all raw materials.

As can be seen, updating old MSDS to new SDS may appear straightforward and simple, which it is in many cases. It is only where new information is available and where chemicals have been reclassified that a new SDS needs to be prepared with relevant labels and training programs. In this area ICSDS excels and helps manufacturers/distributors overcome the compliance barrier. Training conducted side by side helps employees re-evaluate a product and take precautions. Transforming printed data sheets to electronic formats is part of the process that gives users easy access even while they are on the shop floor, something they may not find easy to do with paper documents. ICSDS can claim with pride that its involvement has helped save lives and prevent injuries at workplaces.

Compliance and Training for Hazard Communication Standard by ICSDS

OSHA revised HazCom standard in March 2012 with training to be the starting point of scheduled compliances. OSHA issued technical guidelines in February 2016 for classification of chemicals. The new guidelines call for use of pictograms, revised product labels and new format SDS, all of them contained in a lengthy document running to 432 pages. The guidelines apply to manufacturers and importers of hazardous chemicals and employers using such products in workplaces.

The original HazCom standard is complex and amendments make it even more so. Hazardous nature of a chemical is determined by scientific tests and the hazard class defined just how hazardous it is from the perspective of physical or health. The hazard class has further subdivisions of hazard category according to toxicity and flammability of chemicals. There are four categories. The hierarchy can be confusing, especially when existing MSDS must be updated to SDS and this may necessitate reclassification of a product into the appropriate section. Labels too must reflect the change and provide the right information in the form of signal words, text and pictogram. SDS and labels by themselves are of little use unless workers can learn to interpret them and implement guidelines or follow instructions. This means worker training is imperative to the success of the hazard communication program. Assistance for compliance and training for Hazard Communication Standard by ICSDS proves invaluable for manufacturers/importers mired in the complex maze of hazard class and category distinctions.

What is complex for the layman is not so for experts at ICSDS. They understand the intricacies of the guidance and the multiple appendixes that must also be referred to in the classification of a product and preparation of SDS and labels. The task would be easy if OSHA had a ready to use list from which one can pick the appropriate class and category. ICSDS experts rely on their knowledge of chemicals and draw from other authoritative sources to arive at the right classification/categorization. It must also be kept in mind that there are other agencies involved. For instance, the American Conference of Governmental Industrial Hygienists has a list of threshold limit values of carcinogenic substances.

Though deadlines for compliance have passed and OSHA is lenient, the situation may not continue and non-compliance could result in fines. Speedy updates or preparation of new SDS and labels by ICSDS helps manufacturers avoid this likelihood. At the same time, ICSDS also offers general training on OSHA hazard communication standard 29CFR1910.1200 to bring workers and employees to speed in latest labeling methodologies, pictograms, interpretations and guidelines on safe handling. The concise yet comprehensive course endows workers with full knowledge about 5 key elements of HazCom, their rights under the standard, capability to identify label symbols and other information.

There is no getting away from compliance and it is not possible for staff or employees of a manufacturer or importer to take on the task of SDS/labels or even training given the complexity and chances of errors. Engaging ICSDS, on the other hand, makes it an easy and quick process.

Maintaining Confidentiality of Trade Secrets in REACH Safety Data Sheets

 

Anyone who sells chemicals deemed hazardous in the European Union must comply with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) that came into effect from June 2007. In addition, they also have to content with Regulation 1272/2008 on Classification, Labeling and Packaging (CLP) of substances and mixtures according to UN GHS norms. This is effective from January 2009.

While both are tools to communicate hazards, there is an essential difference. CLP focuses on labeling and REACH specifies rules for the safety data sheets. REACH may apply to quantities above a specified limit whereas CLP applies regardless of quantities involved. REACH SDS registration is mandatory whereas CLP is not mandatory provided chemicals are REACH registered prior to November 2010. The situation can be complex and confusing. This is further compounded by the fact that REACH is more extensive as regards protection of human health and the environment. Chemicals must be categorized and described without any ambiguities in a lengthy process and documentation. REACH safety sheet by icsds.com takes care of all the complexities and makes it easy for manufacturers to do business in the EU without contravening any regulations.

 

It must be kept in mind that full disclosure is required in the process of registration to show a substance’s property and risks. If need be, the authorities may impose restrictions or ban the substance. Full disclosure can pose a problem for manufacturers of proprietary chemical formulations. ICSDS experts adopt a variety of ways to ensure full conformity with REACH regulations while protecting vital trade secrets. A variety of methods may be adopted such as indicating a range of concentration and use of generic names. It may be necessary to apply to EU CLP in order to gain permission to hide composition information. However, REACH SDS will delineate full hazards as may be relevant. This professional and fine-tuned approach by ICSDS protects vital trade secrets of customers without infringing any rules. If necessary, the European Chemicals Agency (ECHA) may be approached to protect confidentiality of proprietary formulations. Experts will make a suitable application along with suitable justifications to reinforce the request for confidentiality. There are procedures to be followed under Article 119(2) and suitable fees to be paid for each item, all of which are taken care of by ICSDS professionals.

ICSDS goes beyond providing SDS services. Their expertise and industry knowledge as well as familiarity with REACH and CLP puts them in a class apart when addressing specific issues such as those of confidentiality of trade secrets. Companies can meet obligations of compliance while being assured that their secrets remain theirs. Should there be any dispute or should a question arise, experts are always available at hand to take on the matter with appropriate authorities.  ICSDS has extensive experience of EU regulations and has served quite a few clients in the past, not only with REACH SDS but also their translation into local languages in addition to training and acting as local representative. ICSDS represents total service for chemical businesses wishing to do business in the EU.

Assure Total GHS Implementation for EU with Professional Assistance

Though the Globally Harmonized System aims at harmony and uniformity in the safe handling, storage and disposal of chemicals, implementation vary from one country to another since they are free to adopt any revision and adopt it in full or part and add further regulations as they may seem fit. This is exactly what countries of the European Union have done. In addition to opting for version 4 of GHS (the latest, 6^th, likely to be implemented in the near future), EU countries also follow EU REACH and CLP regulations. It is mandatory for any chemical company to submit documentation in compliance with their regulations. 

REACH places the burden of GHS implementation on companies to identify and manage risks. It is not only risks related to handling, processing, storage, use and transport but also the safety of downstream user, disposal and effect on environment that is taken into consideration in the EU through REACH. The strange thing about REACH is that an exporter from the US or any other country is not bound by the regulations but the importer in the EU is required to comply with the pre-registration or registration process. This, however, does not absolve exporters because importers will only do business if an exporter is REACH compliant. Also, if quantities involved are below 10 tonnes per annum, some clauses may not apply but for quantities above 1 tonne, it is mandatory. Still, however, regardless of quantities involved, if any manufacturer-exporter wishes to do business in the EU, he must comply with REACH and CLP and this calls for exhaustive and detailed documentation. Now, in addition to the safeguards for storage, use, handling and transport, documentation must also include measures for protection of human health and environment safety through safe disposal advice.  Documents must be in the language of the country to which chemicals are exported. The REACH compliant SDS must be translated in a way that avoids any ambiguity, calling for specialized knowledge of local languages and usages in the countries forming part of the EU. 

 

A company in the US may not have a specific importer-distributor in the EU who is willing to undertake the process. In this case, registration becomes difficult. However, hiring expert GHS implementation companies resolves the issue since they appoint a local representative to carry out the process. 

Why is it so important in the EU? The simple fact is that downstream users are forbidden from using any chemical unless it has an accompanying safety data sheet on use and disposal. Therefore, even if it is a simple cleaning agent or paint or solvent, the product must be REACH compliant and must have the documentation if it is to be sold and bought within the EU and the documentation must be in the local language. This seems a formidable barrier but it becomes easy when one has access to experienced professionals well aware of all REACH regulations and the capability to comply as well as translate documents.

Access to European Markets Becomes Easier with European Safety Data Sheets

American manufacturers/dealers of hazardous chemicals must comply with OSHA-GHS regulations for local processing and trade. Exploring world markets, especially markets of the European Union, necessitates compliance with Regulation EC No 1907/2006 (REACH) and Regulation 1272/2008 (CLP). There are differences to the SDS and compliances under these two regulations. Compliance is necessary, especially when chemicals exceeding 10 tonnes in quantity per year are imported and distributed in the EU. It is a requirement to provide extended safety data sheets known as eSDS also termed as REACH SDS.

Sellers are obligated to supply REACH SDS at the time of first delivery. The European Safety Data Sheets can be in electronic or paper format. This is required when the chemical is termed hazardous. Even if a mixture is not termed as dangerous but if it contains chemicals that may be harmful to human health or to the environment with a concentration of greater than 1%, then the SDS must be supplied and must conform to norms. This applies to chemicals and mixtures that are termed as persistent, bio accumulative and toxic materials or substances of very high concern. REACH SDS may not be insisted upon if the chemical is not hazardous but it facilitates trade.

REACH SDS has some changes. Section 1 requires information on identification of chemical or mixture and the company. Section 2 deals with hazard identification. Section 3 covers composition and information on ingredients. Section 7 covers handling and storage while section 8 deals with exposure controls and personal protection. Section 11 and 12 pertain to toxicological and ecological information. Section 15 relates to regulatory information. SDS must be updated to REACH SDS for hazardous mixtures from December 2015 and when a substance is classified according to CLP regulations. The process is a bit complicated since it requires a manufacturer/exporter to acquire a REACH registration number and follow various steps to include information on exposure scenarios, derived no effect level and predicted no effect concentration. The updated SDS is then called eSDS which may be in hundreds of pages. Further, the document must be translated into the official language of the member state where a manufacturer or exporter does business.

Given these extensive requirements of REACH and CLP, a manufacturer would greatly benefit from professional expertise in compilation of SDS to eSDS and then translatation into the local language. This calls for extreme proficiency and competence in SDS and label authoring services. The authoring service provider must not only be competent about MSDS and SDS in the USA but must have equal knowledge and expertise in EU norms besides possessing translation facilities. Particular attention must be given to translation to ensure the meaning is not lost in the process and this requires knowledge of local jargon and use of standard phrases. This type of expertise may be availed from an established service such as ICSDS that serves American and global clients.  It also happens sometimes that American exporters may have a manufacturing base in an Asian country and expert from there to the EU and the US in which case their expertise in local and international GHS compliances benefit such manufacturers.

Some important guides about REACH SDS EU!

In this present world the need for an adequate safety data sheet is very much important. With so much hazardous products and commodities flaunting the markets, it is necessary that some modes of regulations and formulations are undertaken. These will not only safe-guard the environment as well as the people residing in them as well. The European Union has well understood the need and as a result they have undergone to adopt a technique which will sort of restrict the hazardous products from being dispatched in the market.
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