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HazCOM
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SDS
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GHS
Posted By:
Stefano Battistoni
As you no doubt already know, The Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (HazCom) effective July 19, 2024. The updated Hazard Communication standard (29 CFR Part 1910) concerns classification, labeling and Safety Data Sheet criteria by updating them up to the UN GHS 7th revision.
Some context for the news
The Globally Harmonized System (GHS) is an international framework developed by the United Nations to standardize the classification and labeling of chemicals by using pictograms, signal words, hazard and precautionary statements to classify and communicate the hazardous characteristics of chemicals. The Occupational Safety and Health Organization (OSHA) met the GHS standard in 2012. On May 24, 2024 OSHA updated the standard (via 29 CFR Part 1910) to align with the UN’s 7th revision and parts of the 8th.
Rolling up many years of changes at once
These changes encompass twelve years of incremental updates that, in many cases, have already been in force in Europe for many years; and in Canada, from January 2023. If you are an international manufacturer and already have Trace One SDS Authoring Environment, Health and Safety (EHS) Compliance Software, you will already have many of these updates in the system. But if you do not have an updated, automated way to handle these changes, you have a long road ahead. If your company produces basic chemicals, specialty compounds, fertilizers, detergents, and solvents, you need to get busy.
What changes are included?
OSHA has published a short Q and A on changes to classifications, SDSs and labels. These include:
- Labeling for Small Containers: HazCom 2024 introduced exemptions to some labeling criteria for small containers.
- Safety Data Sheets (SDS):
- Hazards due to change in foreseeable chemical reactions to be communicated in Section 2
- New classification ranges if trade secret is claimed for one or more substances to be reported in Section 3.2
- Additional information required in Section 7 and Section 9 regarding the storage provisions for flammable liquids, if relevant
- Adoption of the GHS UN 7th format and list of chemical properties for Section 9
- Hazard classification
- Expansion of the Classification rooster: adoption of the Desensitized Explosives classification from GHS UN 7th and of the Chemical under pressure classification from GHS UN 8th
- Update of pre-existing Hazard classification: Flammable gases, Aerosols and other physical hazard classification criteria have been updated
- New tiered approach for communicating the “Corrosion to the respiratory tract” potential of the mixture on label
- More flexibility for reporting the Hazard statements related to the Combustible dust classification
Labels will include new or updated hazards, updated guidance, and precautionary statements.
Are there grace periods for this?
The updated standard went into effect on July 19, 2024, but there are phased compliance deadlines for chemical manufacturers, importers and distributors:
- January 19, 2026: Update labels and SDSs for substances.
- July 19, 2027: Update labels and SDSs for mixtures.
The burden on manufacturers can be lessened when an automated system is in place to ingest your suppliers’ SDSs and run a query on all your products impacted by the new standards. Downstream, a good system will also author, generate and print your labeling changes, enabling you to assess the costs involved, plan for production, and ensure you meet all deadlines.
Business impact
Some chemicals you produce will need reclassification according to the expanded or newly added or updated classifications, for example, flammable gases or desensitized explosives. You will need to share updated SDSs and labels with downstream users and train employees on these new requirements.
First steps: Contact your suppliers
The first step is to review your current raw materials suppliers. They should have updated SDSs with the correct information from the updated regulations (for chemical and some personal care manufacturers, the updated classification can be found in Section 2). Because many mixture manufacturers create base mixtures for a wide variety of industries you will obviously ensure all 16 sections of suppliers’ SDSs have the appropriate information.
Review your portfolio for impacted substances
If prior non-hazardous substances are now deemed hazardous, you need to reclassify and relabel these products going forward. All of your chemical substances must be reviewed for the new regulations.
Don’t forget: Expanded end-user impacts are included
The most troublesome part of the new regulations is the end-user classification requirements. For example, if a salon worker is using hairspray made from your mixture, you now must keep them in mind. If they are working with a flat iron at 450-degrees Fahrenheit and are spraying a client’s hair, will the hairspray release formaldehyde, a known irritant? Will build up of product on the flat iron create an unsafe coating that could impact the skin?
Some manufacturers deliver thousands of products to the U.S. market with literally hundreds of thousands of end uses. It is up to mixture manufacturers to do their due diligence and testing on the hazardous ramifications for these users. In practice, that means a lot of research to find and label every product in your portfolio. If you have your suppliers’ SDSs stored in a good EHS software platform, the appropriate designations will be there for other markets, like the EU and Canada.
Enhanced Label Information
Recent regulatory updates address labeling for chemical containers, particularly small containers under 100 ml. While labels on these containers must still be more comprehensive and easier to read, there are exemptions to simplify labeling:
- For containers equal to or smaller than 100 ml:
Labels only need to include essential information such as the Product identifier, pictogram, signal word, chemical manufacturer’s name, phone number, and a note that full label details are provided on the outer package. - For containers even smaller (3 ml or less):
At least, the Product identifier is required on the container label.
Larger containers, like drums or bulk mixtures, will continue to follow the full, comprehensive labeling requirements:
- Pictograms: Standardized pictograms visually alerting workers to potential hazards.
- Signal Words: Signal words like "Danger" and "Warning" indicate the severity of the hazard.
- Hazard Statements: Short statements describe the nature of the hazard.
- Precautionary Statements: Instructions on how to handle the chemical safely.
Second Step: Improved Safety Data Sheets (SDSs)
The 16-section SDS will provide detailed information about chemicals in a standardized format, with clarity, while trade secret can be claimed in order to provide essential hazard information while using updated concentration ranges. You must provide the updated versions to all customers and distributors.
Third Step: Ensure your EHS workflows reflect these new standards
The new requirements, particularly regarding chemical labeling and SDSs, create a brand-new project you need to approach as proactively as possible. You will likely need a project manager and a review process to make sure all your suppliers provide the SDSs in time. You will then need to ensure that all the labeling will be ready before the appropriate compliance date.
If you already have an automated SDS and label authoring EHS system, you are in a better position to align your actions. The mixtures involved will be there in the system, so all you must do is run reports, plan your supplier SDS project, and plan for the new labels for the products. Yes, there may be hundreds of substances involved. But the deadlines are looming.
Let’s say you’re using legacy Enterprise Resource Planning (ERP) systems to handle your HazCom workflows. You’ll need a software platform that works with these enterprise systems to handle these tasks. Ideally, your software can run on batch after hours. You can identify which mixtures are impacted without taking time out of your employees’ normal jobs.
Your SDS and labeling system should already have back-end updates because they’re based in the cloud. So employees, again, can concentrate on value-driven activities instead of administration and upgrades. The system can run GHS regulatory calculations, SDS and label composition, certificate generation, and document distribution–all with a few clicks.
Automated by country, by mixture
It’s crucial to have an authoring tool that also does the following:
- Auto-completion of SDS Section 14 based on UN number selection
- Country translations
- ADR, IATA, IMDG, DOT, TDG, ADG, SCT, and ANTT data for a GHS-based transport calculation. This feature calculates ADR UN numbers compatible with product GHS classifications and other experimental data for the following classes
- Flammable liquids (Class 3 - F1, F2, FT1, FC, FTC)
- Oxidizing substances (Class 5.1 – O1, O2, OT1, OT2, OC1, OC2)
- Toxic substances (Class 6.1 – T1, T2, T3, T4, T5, TF1, TO1, TO2, TC1, TC2, TC3, TC4, TFC)
- Corrosive substances (Class 8 – C1, C2, C3, C4, C5, C6, C7, C8, C9, C10, CF1, CO1, CO2, CT1, CT2)
- Miscellaneous dangerous substances and articles (Class 9 – M6, M7, M9, M10)
The system should also calculate “N.O.S.” shipping names for all these UN numbers, including the data in Table A of Chapter 3.2 of the ADR for the compilation of the SDS, including Tunnel Restriction Codes and special provisions.
You can generate exposure scenarios with a step-by-step, user-friendly interface that makes it easy to insert relevant information in predefined fields. The exposure scenario tool should be based on the Cefic ESCom package and include the ESCom phrase catalog of over 1,600 phrases, including translations in all EU languages. step-by-step, user-friendly interface that makes it easy to insert relevant information in predefined fields. The exposure scenario tool should be based on the Cefic ESCom package and include the ESCom phrase catalog of over 1,600 phrases, including translations in all EU languages.
SDSs–when and where you need them
Your tool should compile an accurate database that keeps track of each SDS: what has been sent, when, and to whom, including when the SDS was last opened. Connected to your ERP systems, it will have the most current list of contacts, a detailed record of SDS distribution, and the last date of purchase. Finding and getting the new SDSs from suppliers that are compliant with the new regulations can be done faster and more accurately–and you can forget about combing through emails to get a status of that crucial step.
Labels done right
Make sure the labeling process in your software includes a way to customize or use fixed text fields and generate GHS and ADR pictograms with all the correct regulatory sentences needed. It also needs to easily generate barcode 1D and all of the new or updated labeling requirements.
Cloud-based functionality
The SDS/label software you choose must have real-time access. This allows you to target the new regulatory classifications for each mixture and keep Quality Assurance aligned and engaged for new and existing products. Cloud-based functionality aligned with ERP integration keeps your system updated when you add new products under these regulations and, of course, for the original updates needed to stay compliant with the new GHS. It should:
- Calculate updates to an SDS based on ERP triggers
- Verify formulas based on TDS updates
- Print labels and other documentation
- Perform classification calculations
- Check product data against new regulations
- Generate and upload PDFs of updated SDSs
Get ahead of the change
There’s a lot to do to make sure you can generate comprehensive and legible labels, detailed 16-section Safety Data Sheets (SDSs), and ultimately meet the compliance deadlines in January and in July. With the right EHS management software, HazCom compliance can be done on time and without causing headaches, hours of overtime, data entry and second-guessing. If you’d like to learn more about how you can better identify impacted mixtures, run regulatory calculations on your portfolio, and generate updated SDSs and labels, contact us.
To calculate your SDS automation ROI, click here.