Beyond SDS Compliance

Many EH&S professionals are unlocking the hidden value in their SDS data, and so can you.

• By Kraig Haberer
• May 01, 2012

For most safety professionals, the role of the safety data sheet (SDS) is one of safety and compliance. Specifically, OSHA's Hazard Communication Standard (HCS) originated in order to protect workers with the "right to know" information about the hazards they were exposed to, the potential harm of those hazards, and the precautionary measures that could prevent or minimize harmful effects. Although initially focused on the workplace, the HCS and other regulations expanded to EPA initiatives and community interest groups demanding information about potential hazards in the air we breathe, the water we drink, and the ground we walk.

However, there is more to the SDS than meets the eye. In fact, there is critical information available on the safety data sheet to help environmental, health, and safety (EH&S) professionals unlock hidden value for their organizations. The goal of this article is to outline how many in the profession are thinking bigger, broader, and more strategically about the role of chemical data in their organization and for their customers.

According to GreenBlue®, a nonprofit that equips business with the science and resources to make products more sustainable, two trends in product sustainability for the next decade include product transparency and producer responsibility. They conclude that product transparency is nearing the tipping point, meaning that not only is the demand for safer, greener products rising, but also the pressure for companies to disclose what's in their products so consumers can make more informed decisions. (GreenBlue.org, Feb. 6, 2012: "The Next Decade: Five Trends in Product Sustainability")

A recent example, hitting close to home for all of us as consumers, is Coca-Cola's and Pepsico's recent decisions to change one of the ingredients for their flagship beverages. A new California regulation requires any beverage containing a certain level of ammonia sulfite, a suspected carcinogen, to come with a cancer warning label. Although the Food and Drug Administration has clearly stated there is no immediate health risk unless the drinks are consumed in huge quantities, this is a good example of how changing consumer and regulatory attitudes are driving manufacturers toward greater product disclosure and transparency.

While the formulation for these products is clearly confidential and proprietary to company officials, the ingredient data and chemical formulation reside within the company's recipe and chemical data information systems. Therefore, unlocking these data and identifying this potential regulatory concern early in the product lifecycle is critical. Proactive EH&S teams are going beyond the typical compliance responsibilities and looking for ways to add value to the development and distribution of their company's products.

What are some examples of valuable chemical data within your safety data sheets? Your SDSs will contain: ingredient data, hazard data, regulatory information, health effects, physical hazards, target organ data, and more. Ways to utilize that information beyond pure compliance efforts range from new product development initiatives to risk management objectives, regulatory reporting automation, and even product sustainability programs. We’ll discuss each of these briefly in the remainder of the article.

New Product Development
For goods-producing companies, the new product development process is the lifeblood of the organization. From research to prototyping and production to recycling, the product lifecycle process requires a significant investment of capital. With respect to unlocking valuable chemical and material data, how important do you think it would be to be able to identify potential market risks and substitute better alternatives at the beginning of the product development process rather than at the end, when all of the investment has already been made?

The right chemical data and management system can help the product teams make informed choices throughout the product lifecycle. It ensures that EH&S becomes an expert partner in the process by arming you with the tools that allow you to cross-reference current or planned chemicals or ingredients with safety, environmental, and even regulatory factors. Some advantages of proactively analyzing chemical and ingredient data within the new product development process include:

• Identification of potential restricted ingredients or materials in the R&D process
• Reduction in late-cycle product redevelopment and recycling costs
• Increase in reputational value by consistently introducing high-quality, low-impact products
• Improvements in EH&S’s ability to add value to the entire product lifecycle management process

Risk Management
Risk management is a broad but important topic for businesses today. It clearly has the attention of all levels of the organization because even when you think you’re doing the right things as a business, sometimes the unforeseen can transform risk into reality and have negative consequences on the bottom line.

Obviously, there is risk involved with hazardous substances, so your job is to help identify, quantify, and control the risks your organization faces. They may be employee health risks (short term and long term), environmental risks, or even market risks. So what can you do to identify, quantify, and control the risk for your organization?

• Leverage the data on the safety data sheet to define and quantify your hazard footprint to both employees and the environment. Your safety data sheets, coupled with an up-to-date regulatory database, include a vast amount of information about the properties, health effects, environmental impact, physical dangers, and regulatory list cross-references that will impact your hazard footprint.
• Electronically scan and cross-reference the regulations against the materials in your work area, facility, and corporation.
• Link material hazard data with work environment factors, such as length of exposure, use, and material volume. Taking a control banding approach to risk assessment and industrial hygiene issues will factor in all of the key ingredients of risk: 1) the inherent risk of the materials, 2) the work environment/exposure risk based on usage and duration, as well as 3) regulatory risk in the countries where you do business.

Regulatory Compliance and Reporting
Regulatory compliance is a complex and detailed portion of the EH&S role. Regulatory compliance in North America alone includes many levels of reporting and material tracking, from Title V/Air Permitting to SARA Reporting for Tier II and Form R-TRI, to industrial hygiene sampling and assessment, to inventory review and more. Depending on the size of a corporation’s global footprint, the list of regulatory needs for compliance can become quite extensive.

Having a system that catalogs, inventories, and manages the chemical data from the safety data sheet is imperative. Additionally, regulatory lists should be cross-referenced to help determine what and where hazardous materials are located on site at any moment. If the associated inventory system is tracking quantities and is integrated with the regulatory compliance system, easily importing that quantity data into a regulatory report will significantly cut down on time and user error caused from duplication of work.

Product Sustainability
Product sustainability initiatives can be described in many ways. At its core, product sustainability embraces the concept of making health, safety, and environmental protection an integral part of the entire lifespan of a product, including design, material sourcing, manufacturing, distribution, service, and disposal or recycling. Product sustainability not only requires the necessary material and regulatory data related to a product, but also a systematic approach to managing and communicating that data and related risks throughout the supply chain and demand chain.

The role of EH&S here is to know the details of your product -- not just the end result, but also the detailed formulation of substances in it and in use during the manufacture of the product. Having an electronic chemical management system will help with this, as well as SDS authoring systems, which will assist in the review, classification, and regulatory cross-referencing of the products you are distributing. Furthermore, chemical management systems can monitor and review changes to material formulations or properties, as well as updated regulatory cross-references that may alter the classification, packaging, or labeling of your products. The goal is to communicate fully the nature, precautions, and substance of your product or the materials your employees and customers are dealing with throughout the supply chain.

Getting Started
Going beyond basic SDS compliance can be good for your company and your career. By leveraging the hidden chemical data on your safety data sheets, the EH&S team has the ability to influence other key areas of the business, including product development, marketing, and supply chain.

To get started, make sure that you have content (chemical data, regulatory content, etc.) in a usable form. Start with collecting and analyzing the chemical data to define your own hazard footprint. Second, get the right tools to identify, analyze, and understand the impact of your chemical data in your raw materials, work-in-process, and finished goods. Oftentimes, a good SDS management system can help.

This article originally appeared in the May 2012 issue of Occupational Health & Safety.