The GHS success path: How-to convert to GHS
How Actio customers are preparing for Globally Harmonized Systems for internationally standardized Safety Data Sheets.
Portsmouth, NH October 30, 2009 -- Actio Corporation, the leading provider of SaaS solutions for supply chain materials information management and environmental compliance, today presented the industry with its program for GHS compliance. Market leading companies are already positioned for GHS - Globally Harmonized System of chemical classification and labeling – and they are reaping the benefits of harmonized data. Any company can prepare for GHS, anytime, and harvest rewards.
The initiative comes on the heels of OSHA's (Occupational Health and Safety Association) announcement recently, on September 30 2009, that it will be pursuing the proposed GHS rule.
GHS is a simple concept – uniformity. A good example is how mailing addresses break down to a certain number and type of field in a certain order: name, street, city, code, etc. Currently, there is no such uniformity in product or substance Material Safety Data Sheets, or (M)SDSs, which is why a GHS standard is needed. GHS will streamline chemical inventory, visibility, disclosure, and reporting – resulting in a greener industrial landscape.
ROI is king
OSHA predicts that GHS will result in cost-savings and high Return on Investment (ROI). The benefits of GHS are expected to be in the hundreds of millions each year. According to the Federal Register, “the net benefits of proposed modifications to the standard are estimated to be $754 million annually."
It's safe to say that the sooner a company starts toward GHS, the sooner the ROI.
“The goal of GHS is to provide a consistent global framework for classifying and identifying chemical hazards,” said Russell McCann, President of Actio Corporation. “Different countries can fine-tune the regulation to their specific initiatives by increasing requirements on toxicological thresholds or exposure.”
The overall key to assessing the full span of information, said McCann, is to have all raw materials identified, down to the substance level, with their ingredient percentages housed in a data library. This information will be collected from (M)SDSs from the raw material suppliers, or from full disclosure documents.
Specific steps to prepare for GHS:
1. Start by weeding out redundant and outdated documents. 33% of (M)SDS or full-disclosure documents are revised each year, so make sure to start with the most up-to-date information.
2. Set up a process to ensure that outreach to suppliers occurs on an ongoing basis. Ongoing outreach is critical – to verify that raw material information remains current for all finished goods, down to the substance level, throughout the year. It’s best if this can be automated, as some software add-on modules will do.
3. Assemble raw materials in a spreadsheet or database application. A relational database is the best approach because your raw material ingredients can be tied to a finished product. If you use formulation software or a formulation database, formula information can be tied to the raw material ingredient information to produce a comprehensive BOM (bill of material) for your finished good. Also, a relational database provides visibility into your materials data, providing huge bonus value for reporting, re-formulating, cost savings in procurement and storage.
4. To produce a GHS-compliant data sheet, validate all data with available references such as toxicological studies, exposure data, and environmental regulatory databases, to name a few. Having all data in a relational database will prove to be essential to maintaining this vast amount of resources. You'll also have to examine how materials and mixtures fit under the GHS classifications. Once the data is aligned, you can begin creating GHS compliant (M)SDSs and labels.
5. The remaining requirements are very similar to the existing HCS: you must train your employees on the new data sheets, produce labels that reflect the information contained on the (M)SDS, and train your employees on the safe handling of raw materials and finished goods.
It may sound like a lot, but it pays off almost immediately and then keeps on returning. It might be worth bringing in experts to expedite the conversion process and make sure it's done right. It can be less costly to have an experienced team approach it rather than to subsidize an internal team who has never done anything like it before.
There more efficient the conversion, the more meaningful the cost savings.
Cost$ Database OSHA will then review all materials and publish its findings. There is no date set for final hearings on feedback or on publication. ###
GHS compliance will make business run more smoothly, encourage material disclosure, and facilitate international trade. For instance, OSHA estimates that with standardized data sheets, the time savings per SDS review is 2.5 to 4 hours each. That's an astonishing figure.
OSHA further estimates the average salary of the person reviewing the SDS to be $47/hour. If your department reviews an average of three (M)SDSs per day, that's a $141 savings each day, and $36,660 each year. You would have to do the math for your organization, but in (M)SDS review alone GHS conversion provides immediate ROI.
That savings from data review is merely a fraction of the savings OSHA estimates. OSHA estimates time-to-market ROI, international trade cost reduction, and savings resulting from greater job safety and less injury.
Also to consider are cost savings in Six Sigma initiatives resulting from streamlined processes; never mind cost-savings in time, paper and clerical labor, and the priceless ease-of-reporting to stakeholders such as the EPA, REACH agencies, any regulatory bodies, customers, board members, the public at large. And of course there are huge risk management returns to consider.
Every manager knows that having substance-level data in a centralized, relational database is not just a progressive notion anymore - it's a necessity. There are regulations that require visibility into product information which can only be attained this way. There is immediate ROI in streamlining operations by relinquishing paper-based systems. Further, there is also ROI in how data can be leveraged and reused - along with the added benefit of making the project lead look like a substance-data and environmental compliance virtuoso.
The data converted to GHS can be leveraged for Corporate Social Responsibility initiatives, Public Relations, Marketing, Environmental Compliance, and Governance statements.
Regardless of how we all get through the steps to GHS, we'll be glad we did. The conversion is inevitable. We may as well convert consciously, even enthusiastically. It could be a great thing for your company, for the career of whomever is at the helm, for employee safety, and a greener environment.
The process of converting to GHS can be done for you, and can be automated going forward, and the investment does not have to break the bank. Conversion programs offered by Actio Corporation and others in the Green Tech space can help.
GHS key deadlines- when do you really have to get moving?
A proposed GHS Rule and a Request for Comments was posted on September 30, 2009 in the OSHA Federal Register. December 31, 2009 is the first deadline, it's for submission of comments on the proposed GHS rule. If you have any feedback on the proposed rule, have it submitted by then.
There will be a grace period after publication of the rule, during which companies will engage in a rush to become compliant, and prices for conversion help will escalate.
How to get a free GHS Conversion evaluation
Some companies have been (M)SDS data to standardized data sheets for so long that they can very fluidly and quickly survey your situation and provide an evaluation and overview of how to proceed. This should be a complimentary service, but be sure to ask up front to make sure.
Actio Corporation provides a complimentary service. “It’s in everyone's best interest to get companies on the road to GHS,” said Christian Nowak, Actio's GHS Program Manager. “And Actio can make it easy. We have SDS authoring software, relational databases designed for the substance level, BOM-tracking and material disclosure modules – ready to go. We’ve been doing this for ten years,” he said.
Additionally, more progressive technology can make GHS conversion a launch-pad for greening and managing supply chain data. Some software can evaluate your product data library and link raw materials to the finished goods. Knowing the ingredients empowers your organization to migrate data into a database for distribution to requestors.
Some companies have been innovators in green initiatives on many fronts. Bear in mind there is still a window to evaluate your GHS program and decide to get started – before the rush.
About Actio Corporation
Actio's materials information management solutions are architected as web-native SaaS (software as a service) applications that utilize a unique relational database structure to manage global regulatory information, substance data, and supplier content in a single, secure platform. Actio enjoys a successful track record with 250 customers in 35 countries, including dozens in the Fortune 500. For more information, please call Corporate Headquarters at +1 866-522-8102.
Kathleen Hurley, Director, Corporate Communications
603-433-2300 x35 | @actiocorp | firstname.lastname@example.org
Kal Kawar, Professional Engineer (PE) and Certified Industrial Hygienist (CIH, contributed to this article. Kawar is a member of and speaker for many related associations, and is co-Founder of Actio Corporation, materials data management specialists for hazcom, enterprise, and supply chains.
OSHA will then review all materials and publish its findings. There is no date set for final hearings on feedback or on publication.