Katie McGee, Regulatory Content Manager at SiteHawk explores the reality of compliance in the "post-GHS" landscape and suggests actionable strategies to help Safety Manager's move closer to full compliance.
SEND Solutions. Efficient. Enlightening, Info Sheet Covance
The Standard for the Exchange of Nonclinical Data (SEND) is the new FDA electronic, standardized format for submitting your nonclinical study data with increased efficiency. Plus, it's so much more. SEND delivers an enlightening new view of your nonclinical study data that enables you to gain fresh insights and a valuable research database while complying with the FDA regulations.
PANEL 4: Speeding up chemical assessments: from novel information to new management approaches, what works? - Erika Kunz, Head of Global Registration and Evaluation of Chemicals, Clariant, Germany
PANEL 4: Speeding up chemical assessments: from novel information to new management approaches, what works? - Brian Richards, Executive Director, Office of Chemical Safety, Australia
SEND Solutions. Efficient. Enlightening, Info Sheet Covance
The Standard for the Exchange of Nonclinical Data (SEND) is the new FDA electronic, standardized format for submitting your nonclinical study data with increased efficiency. Plus, it's so much more. SEND delivers an enlightening new view of your nonclinical study data that enables you to gain fresh insights and a valuable research database while complying with the FDA regulations.
PANEL 4: Speeding up chemical assessments: from novel information to new management approaches, what works? - Erika Kunz, Head of Global Registration and Evaluation of Chemicals, Clariant, Germany
PANEL 4: Speeding up chemical assessments: from novel information to new management approaches, what works? - Brian Richards, Executive Director, Office of Chemical Safety, Australia
How closely does Environmental, Health, and Safety (EH&S) monitor chemicals with the potential to form peroxides within the laboratories of your company? How well aware are your researchers of which chemicals these are and how to handle and dispose of them? Proper management of potential peroxide-forming solvents is vital to the safety of your researchers and facility staff, the compliance of your institution, the maintenance of your laboratory peroxide-forming chemical equipment and research materials, and the cost of your waste disposal. Take a look to find out everything you need to know about the hazards and handling of advanced peroxide forming chemicals.
ScienceCloud: Collaborative Workflows in Biologics R&DBIOVIA
The life sciences industry has undergone dramatic changes and effective global collaboration has become a key success factor in this new age. BIOVIA is providing a hosted and comprehensive solution stack for externalized, collaborative research for pharma/biotech and CROs to address these new challenges. Recently we added the support for biologics data management and IP capture. In this talk we will present collaborative and comprehensive capabilities in antibody characterization and development: capabilities to analyze, annotate and predict developability as part of a framework that facilitates secure data sharing and collaboration.
This webinar provided an overview of how to effectively manage peroxide formers, beginning with training and identification. Our expert shared real-world examples of institutions that have struggled with and rectified their peroxide former problems.
The Laboratory Analytical and Life Science Instrument Industries: Looking Ahe...Bill Kelly
We take a look at the market hotspots to watch in 2018 for the Laboratory Analytical and Life Science Instrument Industries by giving you an overview of the market by the numbers and highlight specific industries including spectroscopy, chromatography, diagnostics, and laboratory software.
Structure-Based Drug Design Facts & Figures InfographicJames Prudhomme
Among 32 pharma and biotech companies surveyed, structure-based drug design is the most prevalent activity with the most players emphasizing the fragment-based variation.
This presentation provides insight into how to manage peroxide formers in a streamlined, cost effective way. You will learn how to create and implement a peroxide former management plan and see how other institutions have rectified their peroxide former problems through multiple case studies and real-world scenarios.
ValGenesis Case Study With Scinopharm -Paperless Validation Software Solution ValGenesis
ValGenesis delivered a validated and qualified system in six weeks – the rapid implementation we needed. The system has been stable from the start, with little need for customer support calls, allowing us to focus on training and bringing on new users every week.”
— Steve Johnson, Director, Operations
Injectable Facility
ScinoPharm Taiwan, Ltd.
Opportunities and Challenges Associated with Novel Companion Diagnostic Techn...L.E.K. Consulting
L.E.K. Managing Director Alex Vadas spoke at a BDA workshop on "How to Mature Emerging Technologies into Companion Diagnostics?" See his presentation here.
Jim Jones, US EPA Acting Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, delivered the keynote presentation at the Commission for Environmental Cooperation's (CEC) Chemicals Management Forum held in San Antonio, Texas, on May 15, 2012
How to Become a Thought Leader in Your NicheLeslie Samuel
Are bloggers thought leaders? Here are some tips on how you can become one. Provide great value, put awesome content out there on a regular basis, and help others.
Introduction to Project Management for College StudentsRahul Dronamraju
I made this presentation as a part of series of lectures I gave in conjunction with IEEE aimed at College Students. I used the slides as background to detail my experiences, along with presenting the LMS used by my former employer (TCI).
Note: I have used images made by people more creative/funnier than me, and have used the citations or have written to the people asking for permission, in case anyone needs confirmations.
How closely does Environmental, Health, and Safety (EH&S) monitor chemicals with the potential to form peroxides within the laboratories of your company? How well aware are your researchers of which chemicals these are and how to handle and dispose of them? Proper management of potential peroxide-forming solvents is vital to the safety of your researchers and facility staff, the compliance of your institution, the maintenance of your laboratory peroxide-forming chemical equipment and research materials, and the cost of your waste disposal. Take a look to find out everything you need to know about the hazards and handling of advanced peroxide forming chemicals.
ScienceCloud: Collaborative Workflows in Biologics R&DBIOVIA
The life sciences industry has undergone dramatic changes and effective global collaboration has become a key success factor in this new age. BIOVIA is providing a hosted and comprehensive solution stack for externalized, collaborative research for pharma/biotech and CROs to address these new challenges. Recently we added the support for biologics data management and IP capture. In this talk we will present collaborative and comprehensive capabilities in antibody characterization and development: capabilities to analyze, annotate and predict developability as part of a framework that facilitates secure data sharing and collaboration.
This webinar provided an overview of how to effectively manage peroxide formers, beginning with training and identification. Our expert shared real-world examples of institutions that have struggled with and rectified their peroxide former problems.
The Laboratory Analytical and Life Science Instrument Industries: Looking Ahe...Bill Kelly
We take a look at the market hotspots to watch in 2018 for the Laboratory Analytical and Life Science Instrument Industries by giving you an overview of the market by the numbers and highlight specific industries including spectroscopy, chromatography, diagnostics, and laboratory software.
Structure-Based Drug Design Facts & Figures InfographicJames Prudhomme
Among 32 pharma and biotech companies surveyed, structure-based drug design is the most prevalent activity with the most players emphasizing the fragment-based variation.
This presentation provides insight into how to manage peroxide formers in a streamlined, cost effective way. You will learn how to create and implement a peroxide former management plan and see how other institutions have rectified their peroxide former problems through multiple case studies and real-world scenarios.
ValGenesis Case Study With Scinopharm -Paperless Validation Software Solution ValGenesis
ValGenesis delivered a validated and qualified system in six weeks – the rapid implementation we needed. The system has been stable from the start, with little need for customer support calls, allowing us to focus on training and bringing on new users every week.”
— Steve Johnson, Director, Operations
Injectable Facility
ScinoPharm Taiwan, Ltd.
Opportunities and Challenges Associated with Novel Companion Diagnostic Techn...L.E.K. Consulting
L.E.K. Managing Director Alex Vadas spoke at a BDA workshop on "How to Mature Emerging Technologies into Companion Diagnostics?" See his presentation here.
Jim Jones, US EPA Acting Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, delivered the keynote presentation at the Commission for Environmental Cooperation's (CEC) Chemicals Management Forum held in San Antonio, Texas, on May 15, 2012
How to Become a Thought Leader in Your NicheLeslie Samuel
Are bloggers thought leaders? Here are some tips on how you can become one. Provide great value, put awesome content out there on a regular basis, and help others.
Introduction to Project Management for College StudentsRahul Dronamraju
I made this presentation as a part of series of lectures I gave in conjunction with IEEE aimed at College Students. I used the slides as background to detail my experiences, along with presenting the LMS used by my former employer (TCI).
Note: I have used images made by people more creative/funnier than me, and have used the citations or have written to the people asking for permission, in case anyone needs confirmations.
HEAG Wohnbau GmbH - Roter Teppich für Immobilien-Eigentümer und StudentenHeag Wohnbau
Die HEAG Wohnbau ist in den Bereichen Immobilienwirtschaft und Immobiliendienstleistungen tätig. Das Kerngeschäft ist die Wohnungswirtschaft. Zur Wohnungswirtschaft gehört die Bewirtschaftung eigener und fremder Mietwohnungen, die Bewirtschaftung eigener und fremder Gewerbeimmobilien sowie die Bewirtschaftung von fünf fremden Studentenwohnheimen. Die Geschäftsfelder Eigentumsverwaltung und Maklerservice runden das Leistungsportfolio der HEAG Wohnbau ab.
The technologies and people we are designing experiences for are constantly changing, in most cases they are changing at a rate that is difficult keep up with. When we think about how our teams are structured and the design processes we use in light of this challenge, a new design problem (or problem space) emerges, one that requires us to focus inward. How do we structure our teams and processes to be resilient? What would happen if we looked at our teams and design process as IA’s, Designers, Researchers? What strategies would we put in place to help them be successful? This talk will look at challenges we face leading, supporting, or simply being a part of design teams creating experiences for user groups with changing technological needs.
HazCom 2012 Changes Introduced by the GHS: Upcoming Changes and Your Responsi...Sarah Sajedi
The June 1, 2015 GHS Compliance deadline introduces some changes to hazard communication sheets (SDSs) and labels. This presentation outlines the changes to hazard communication you should expect as well as your responsibilities.
Global Regulatory Outlook: 2017 and Beyond - OMTEC 2017April Bright
Keeping a finger on the pulse of regulatory changes taking place worldwide is hard to do, but nonetheless imperative. This presentation will provide a high-level overview of the more significant global regulatory changes that will impact orthopaedic manufacturers in the next two years. These include European Medical Device Regulation, ISO 13485:2016, MDSAP and U.S. FDA changes, as well as other global topics of interest. Ms. Loh, who leads the regulatory team at EMERGO, returned to OMTEC to provide perspective on strategies and risks to consider with these wide-ranging and sometimes overlapping matters.
This presentation will highlight the actions you should take now in order to successfully transition to the updated standard.
PANEL 3: Priority setting of chemicals – potential for harmonisation and synergies
Presentation: Mike Rasenberg, Head of Computational Assessment and Dissemination Unit, ECHA
A presentation given by ReAgent's Systems Manager, Graham Bayliss. The presentation was given at an event run by Chemicals Northwest in Runcorn. It discusses how REACH impacts at ReAgent and other ways it is used in industry.
2013 Year of Pharmaceutical Serialization - Get it RightMichael Stewart
Pharmaceutical serialization en mass will occur in 2013 due to US and es-US regulations to track products at the item level. Michael Stewart of PharmTech Inc. shares his insight into the project Management pitfalls and allows you to use his learning curve working with top 10 pharmaceutical manufacturers, contract manufacturers and virtual manufactures to get ROI and business value in addition to compliance. Turn a perceived cost into an investment.
The Brazilian Path to Establish Legal and Administrative Infrastructure to th...MyChemicalMonitoring
Presentation from Letícia Reis de Carvalho,
Director at the Departament of Environmental Quality in the industry
Ministry of the Environment, at the ICCM4 (September/October 2015)
Micro RNA genes and their likely influence in rice (Oryza sativa L.) dynamic ...Open Access Research Paper
Micro RNAs (miRNAs) are small non-coding RNAs molecules having approximately 18-25 nucleotides, they are present in both plants and animals genomes. MiRNAs have diverse spatial expression patterns and regulate various developmental metabolisms, stress responses and other physiological processes. The dynamic gene expression playing major roles in phenotypic differences in organisms are believed to be controlled by miRNAs. Mutations in regions of regulatory factors, such as miRNA genes or transcription factors (TF) necessitated by dynamic environmental factors or pathogen infections, have tremendous effects on structure and expression of genes. The resultant novel gene products presents potential explanations for constant evolving desirable traits that have long been bred using conventional means, biotechnology or genetic engineering. Rice grain quality, yield, disease tolerance, climate-resilience and palatability properties are not exceptional to miRN Asmutations effects. There are new insights courtesy of high-throughput sequencing and improved proteomic techniques that organisms’ complexity and adaptations are highly contributed by miRNAs containing regulatory networks. This article aims to expound on how rice miRNAs could be driving evolution of traits and highlight the latest miRNA research progress. Moreover, the review accentuates miRNAs grey areas to be addressed and gives recommendations for further studies.
Diabetes is a rapidly and serious health problem in Pakistan. This chronic condition is associated with serious long-term complications, including higher risk of heart disease and stroke. Aggressive treatment of hypertension and hyperlipideamia can result in a substantial reduction in cardiovascular events in patients with diabetes 1. Consequently pharmacist-led diabetes cardiovascular risk (DCVR) clinics have been established in both primary and secondary care sites in NHS Lothian during the past five years. An audit of the pharmaceutical care delivery at the clinics was conducted in order to evaluate practice and to standardize the pharmacists’ documentation of outcomes. Pharmaceutical care issues (PCI) and patient details were collected both prospectively and retrospectively from three DCVR clinics. The PCI`s were categorized according to a triangularised system consisting of multiple categories. These were ‘checks’, ‘changes’ (‘change in drug therapy process’ and ‘change in drug therapy’), ‘drug therapy problems’ and ‘quality assurance descriptors’ (‘timer perspective’ and ‘degree of change’). A verified medication assessment tool (MAT) for patients with chronic cardiovascular disease was applied to the patients from one of the clinics. The tool was used to quantify PCI`s and pharmacist actions that were centered on implementing or enforcing clinical guideline standards. A database was developed to be used as an assessment tool and to standardize the documentation of achievement of outcomes. Feedback on the audit of the pharmaceutical care delivery and the database was received from the DCVR clinic pharmacist at a focus group meeting.
Artificial Reefs by Kuddle Life Foundation - May 2024punit537210
Situated in Pondicherry, India, Kuddle Life Foundation is a charitable, non-profit and non-governmental organization (NGO) dedicated to improving the living standards of coastal communities and simultaneously placing a strong emphasis on the protection of marine ecosystems.
One of the key areas we work in is Artificial Reefs. This presentation captures our journey so far and our learnings. We hope you get as excited about marine conservation and artificial reefs as we are.
Please visit our website: https://kuddlelife.org
Our Instagram channel:
@kuddlelifefoundation
Our Linkedin Page:
https://www.linkedin.com/company/kuddlelifefoundation/
and write to us if you have any questions:
info@kuddlelife.org
Characterization and the Kinetics of drying at the drying oven and with micro...Open Access Research Paper
The objective of this work is to contribute to valorization de Nephelium lappaceum by the characterization of kinetics of drying of seeds of Nephelium lappaceum. The seeds were dehydrated until a constant mass respectively in a drying oven and a microwawe oven. The temperatures and the powers of drying are respectively: 50, 60 and 70°C and 140, 280 and 420 W. The results show that the curves of drying of seeds of Nephelium lappaceum do not present a phase of constant kinetics. The coefficients of diffusion vary between 2.09.10-8 to 2.98. 10-8m-2/s in the interval of 50°C at 70°C and between 4.83×10-07 at 9.04×10-07 m-8/s for the powers going of 140 W with 420 W the relation between Arrhenius and a value of energy of activation of 16.49 kJ. mol-1 expressed the effect of the temperature on effective diffusivity.
Willie Nelson Net Worth: A Journey Through Music, Movies, and Business Venturesgreendigital
Willie Nelson is a name that resonates within the world of music and entertainment. Known for his unique voice, and masterful guitar skills. and an extraordinary career spanning several decades. Nelson has become a legend in the country music scene. But, his influence extends far beyond the realm of music. with ventures in acting, writing, activism, and business. This comprehensive article delves into Willie Nelson net worth. exploring the various facets of his career that have contributed to his large fortune.
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Introduction
Willie Nelson net worth is a testament to his enduring influence and success in many fields. Born on April 29, 1933, in Abbott, Texas. Nelson's journey from a humble beginning to becoming one of the most iconic figures in American music is nothing short of inspirational. His net worth, which estimated to be around $25 million as of 2024. reflects a career that is as diverse as it is prolific.
Early Life and Musical Beginnings
Humble Origins
Willie Hugh Nelson was born during the Great Depression. a time of significant economic hardship in the United States. Raised by his grandparents. Nelson found solace and inspiration in music from an early age. His grandmother taught him to play the guitar. setting the stage for what would become an illustrious career.
First Steps in Music
Nelson's initial foray into the music industry was fraught with challenges. He moved to Nashville, Tennessee, to pursue his dreams, but success did not come . Working as a songwriter, Nelson penned hits for other artists. which helped him gain a foothold in the competitive music scene. His songwriting skills contributed to his early earnings. laying the foundation for his net worth.
Rise to Stardom
Breakthrough Albums
The 1970s marked a turning point in Willie Nelson's career. His albums "Shotgun Willie" (1973), "Red Headed Stranger" (1975). and "Stardust" (1978) received critical acclaim and commercial success. These albums not only solidified his position in the country music genre. but also introduced his music to a broader audience. The success of these albums played a crucial role in boosting Willie Nelson net worth.
Iconic Songs
Willie Nelson net worth is also attributed to his extensive catalog of hit songs. Tracks like "Blue Eyes Crying in the Rain," "On the Road Again," and "Always on My Mind" have become timeless classics. These songs have not only earned Nelson large royalties but have also ensured his continued relevance in the music industry.
Acting and Film Career
Hollywood Ventures
In addition to his music career, Willie Nelson has also made a mark in Hollywood. His distinctive personality and on-screen presence have landed him roles in several films and television shows. Notable appearances include roles in "The Electric Horseman" (1979), "Honeysuckle Rose" (1980), and "Barbarosa" (1982). These acting gigs have added a significant amount to Willie Nelson net worth.
Television Appearances
Nelson's char
Natural farming @ Dr. Siddhartha S. Jena.pptxsidjena70
A brief about organic farming/ Natural farming/ Zero budget natural farming/ Subash Palekar Natural farming which keeps us and environment safe and healthy. Next gen Agricultural practices of chemical free farming.
UNDERSTANDING WHAT GREEN WASHING IS!.pdfJulietMogola
Many companies today use green washing to lure the public into thinking they are conserving the environment but in real sense they are doing more harm. There have been such several cases from very big companies here in Kenya and also globally. This ranges from various sectors from manufacturing and goes to consumer products. Educating people on greenwashing will enable people to make better choices based on their analysis and not on what they see on marketing sites.
7. What GHS Is…
• Developed by the United Nations
• Based on existing systems (US, EU, Canada and UN
TDG)
• First edition published 2003
• Includes classification criteria and hazard communication
elements
• Many anticipated benefits
The Basics
Protection
ApplicationFacilitation
Evaluation
8. Building Blocks of GHS
Hazard Classes and Categories are the building blocks of GHS and
each competent agency adopts the blocks that are applicable to them.
Category 1-4
Skin
Acute
Toxicity
Explosives
Category 1-6
Health Physical
11. What Happened: GHS Adoption
U.S. Adoption – OSHA 2012
New Elements
• Most hazards retained
• MSDS becomes SDS
• More specific SDS & label
content required
• Prescribed HazCom elements
• New Hazard classes
• Some Non-GHS elements
Existing Elements
12. What Happened: GHS Adoption
Global Disharmony: Communication
WHMIS 2015 Pictograms EU CLP – EUH Phrases
13. What Happened: GHS Adoption
Global Disharmony: Criteria
OSHA 2012 EU CLP
14. What Happened: GHS Adoption
Business Impact
• Manufacturers/Distributors/Suppliers:
• Authoring SDSs for all products
• New labels
• Employers
• New SDSs for all products used
• Training employees
• Workplace labeling requirements
Business Impact
16. What Really Happened?
Business and Transition: MSDS to SDS
Vendor Business Decision
Save Money - Combine SDSs
Products now on separate SDSs
New system – missing product
codes; data not migrated in time;
Authoring SDSs not considered
document management
Authoring independent of product
packaging
17. What Really Happened?
Business and Transition: MSDS to SDS
Employer
3 MSDSs become 1 SDS
1 MSDS becomes 10 SDSs
Material Identification on SDS vs
MSDS different
Differences in how the information
relates to the SDS
Gaps in label generation and
practical application
20. Total Facility A:
Total Records 1303
GHS SDS Records 841
% of facility SDSs that are GHS SDSs 65%
Records w/ Revision Date older 5/1/2012:
Total Records older than 5/1 104
Total SDS Records 1303
% of facility SDSs older than 5/1/2012 8%
Records w/ Revision Date 6/1/2015 and newer:
(Post OSHA & EU CLP Deadline)
Total Records 6/1/2015 and newer 575
Total SDS Records 1303
% of facility SDSs 6/1/2015 and newer 44%
GHS Impact: The Reality
Total Facility B:
Total Records 904
GHS SDS Records 212
% of facility SDSs that are GHS SDSs 23%
Records w/ Revision Date older 5/1/2012:
Total Records older than 5/1 483
Total SDS Records 904
% of facility SDSs older than 5/1/2012 53%
Records w/ Revision Date 6/1/2015 and newer:
(Post OSHA & EU CLP Deadline)
Total Records 6/1/2015 and newer 77
Total SDS Records 904
% of facility SDSs 6/1/2015 and newer 9%
21. GHS Impact: The Reality
61%
SDS Master Catalog (Rev Date 5/1/2012-current)
GHS Non-GHS
65%
Facility A
GHS Non-GHS
23%
Facility B
GHS Non-GHS
GHS Documents: Facility vs. Master Catalog
23. Common Questions
GHS: Next Steps
Why are our documents not GHS-compliant?
Does the title “Safety Data Sheet” mean a document is updated?
What are these new hazards on our raw materials?
3 SDSs for the same raw material have different information. Why?
Manufacturer/Distributor business decisions; outdated products or mismatched SDSs
New GHS hazards and threshold changes
No
Same substance may have different classifications
across agencies or distributors.
24. GHS: Next Steps
• Tidy up
• Label or bar code materials
• Planning
• Create chemical areas
• Be thorough/Be detailed
• Audit as you go
• Consider inventory software
• Develop a routine inventory schedule
Take Inventory
How can workplaces drive compliance?
25. Action Your Inventory
• Plan and budget for resources to use inventory
information
• Acquire GHS SDSs for existing products
• Identify and acquire new product SDSs
• Identify and archive old product SDSs/MSDSs
• Assign/remove existing chemicals from chemical
areas
GHS: Next Steps
28. Resources
UN GHS Purple Book
OSHA HCS 2012
OSHA Fall 2016 regulatory agenda item
SiteHawk Resources: Whitepaper - “8 Tips to Get a Grip on Your
Chemical Inventory” & “5 W’s of Chemical Inventory” infographic. Sign up
during the session. Free copies of the whitepaper can also be accessed
at SiteHawk’s website.
Katie McGee
Regulatory Content Manager
kmcgee@sitehawk.com
Sitehawk.com
At a professional conference on hazard communication in late 2015 a speaker from one of the largest chemical companies in the world provided an analogy that GHS started out as a raindrop and progressed to a storm then a hurricane.
In 2015 her belief that we were in the midst of this and it seemed we would continue to be for a few years. I think that we have started to transition out of the hurricane.
Today we are going to start by taking a retrospective look at UN GHS - Why it came to be, what it is, what it isn’t, the impact to regulations, business and the challenges that have been created in managing documents. Then from there we’ll review how the transition to GHS is going both at a very high level and as part of that we’ll also take a look at a case study on different approaches to the transition. Then finally we’ll talk about what to expect from GHS going forward and what you can do.
Chemicals are used globally
BUT there was no standardized way to communicate hazards of materials in the global market before GHS. All the systems used many different sets of criteria and also different ways to convey information on hazards.
Ultimately the regulatory systems that provide for criteria on how hazards are communicated all have the same purpose
Many benefits to harmonized system were proposed (we’ll talk about what the proposed benefits to harmonization in a minute.
Developed by the UN
Based on existing systems (US & Canada – workplace, consumer and pesticide, EU directives for classification and labeling of substances and preparations, UN TDG systems were reviewed and used as a basis for GHS). When you look at the GHS criteria you can see where the elements of each of these were incorporated into what became GHS.
First edition published 2003
Includes classification criteria and hazard communication elements for hazard classes and categories. Hazard communication elements being signal words, classifications, Hazard statements, pictograms and precautionary statements.
It was also set up to include something called the building block approach – which was that regulatory bodies can adopt the hazard classes, categories and classification criteria by taking the pieces that fit best into their existing regulatory frameworks.
The anticipated benefits of using GHS expected to come from standardized criteria and communication. These benefits included:
Improved protection to people and environment
Help countries with no hazcom program
Facilitate trade
Reduce testing and evaluation of chemicals
The expectation years ago was that SDSs would some day be globally documents. Ie one SDS could satisfy the requirement for an SDS anywhere. Expectations don’t not always become reality
Want to be advise people to be very careful in taking the information from this slides –
By GHS I mean the purple book itself and not any jurisdiction’s regulations based on GHS.
Mandatory – until the GHS criteria are adopted by a regulatory body (OSHA) there is no binding obligation to use the criteria. No GHS police.
Complete – While GHS does cover a large number of hazards there are some hazards that it does not yet cover (Combustible Dust, Static Accumulator, Metal Fume Fever, simple asphyxiant and others)
Static - GHS is a living document. A new edition comes out every two years. There have been 6 revisions that have both amended existing hazard classes and added entirely new hazard classes since the standard was published initially.
Something else that GHS now that we have adoption by a number of regulatory bodies – is not is harmonized.
OSHA adopted GHS with an update to the OSHA HazCom Standard that was deemed “OSHA 2012”
OSHA Adoption of GHS = most GHS hazard classes and categories + some unique OSHA only extras that were outside the scope of GHS (things like simple asphyxiant and combustible dust)
Adoption of GHS also added other new requirements to OSHA HCS things like:
Prescribed hazard communication elements based on classification
More information that must be included on SDSs and standardized SDS format
More stringent cut-offs for mixture classification – no longer the straightforward 0.1 carcinogen and 1% thresholds for all other hazards
Here are a few examples of some of the areas where things are not harmonized.
Another example where things are not harmonized.
In the SDS to MSDS conversion companies often had to make business decisions to get their documents authored with in the confines of the 3 year transition period. These business decisions have consequences for SDS management downstream. Here are some of the Business decisions related to SDSs:
Combining products onto one SDS – this is going to be an expensive conversion – what can we do to minimize the cost and then updates to these documents going forward.
Separating products out onto different SDSs – now with the new
Switching to new authoring systems – system migrations are never pretty and can sometimes be painful. Things that can occur can be loss of data or functionality, especially when faced with a time crunch. Causing identification information on the SDSs to be different.
Changing identifiers on SDSs – maybe the new system doesn’t allow for them, maybe it was an oversight in the transition
Breakdown in communication – we know from experience that when things on an MSDS or SDS have changed even when you call the vendor you don’t always get the same explanation as to why the change has occurred. First example - Series of SDSs with same name, but each has a different product code – one rep says yes, the SDSs that all have the same name are the same regardless of the product code, another rep says each name/code combination is a unique SDS that will have different information. Second example – I have heard of scenarios where service reps in the field for some companies did not even know there were updated SDSs available until they asked if there were plans to update their MSDSs to SDSs. Come to find out there had been updated SDSs available since well before the 2015 deadline.
Authoring is independent of product packaging – the SDS is authored and then the label is created and product packaged. I know from conversations in reality there are gaps in this in terms of practical application.
Authoring does not consider how the document will be used and the downstream effects ie how the information relates to previous SDS.
Now that you have some insight into the business decisions let’s take a look at the employer requirements and then the indirect consequences of these business decisions for employers and SDS management.
In electronic systems there is often additional data (like quantities or locations) beyond the just an MSDS or SDS with any record – so when 3 SDSs become 1 – if the single new SDS is uploaded – which record should remain – or do all 3 get updated causing triplicate costs for what is now one SDS. If you are managing in binders – did you look enough to catch the MSDSs if the other products are being used that should now be archived?
Similarly – when 1 MSDS becomes 10 SDSs – in an electronic system – where all that was tracked was all 10 names – which SDS is applicable – you don’t want to manage and pay for all 10 if you don’t need to. And again – there is that facility data.
These challenges lead to some questions -
SiteHawk has had a front row seat to the MSDS to SDS transition as a SDS management software and services provider. We have a collection of SDSs from thousands of global clients across a broad range of industries that allows us a unique perspective on SDSs. From this information we can give some insight into the GHS status of SDSs as a whole.
In the SDS to MSDS conversion companies often had to make business decisions to get their documents authored with in the confines of the 3 year transition period. These business decisions have consequences for SDS management downstream. Here are some of the Business decisions related to SDSs:
Combining products onto one SDS – this is going to be an expensive conversion – what can we do to minimize the cost and then updates to these documents going forward.
Separating products out onto different SDSs – now with the new
Switching to new authoring systems – system migrations are never pretty and can sometimes be painful. Things that can occur can be loss of data or functionality, especially when faced with a time crunch. Causing identification information on the SDSs to be different.
Changing identifiers on SDSs – maybe the new system doesn’t allow for them, maybe it was an oversight in the transition
Breakdown in communication – we know from experience that when things on an MSDS or SDS have changed even when you call the vendor you don’t always get the same explanation as to why the change has occurred. First example - Series of SDSs with same name, but each has a different product code – one rep says yes, the SDSs that all have the same name are the same regardless of the product code, another rep says each name/code combination is a unique SDS that will have different information. Second example – I have heard of scenarios where service reps in the field for some companies did not even know there were updated SDSs available until they asked if there were plans to update their MSDSs to SDSs. Come to find out there had been updated SDSs available since well before the 2015 deadline.
Authoring is independent of product packaging – the SDS is authored and then the label is created and product packaged. I know from conversations in reality there are gaps in this in terms of practical application.
Authoring does not consider how the document will be used and the downstream effects ie how the information relates to previous SDS.
Now that you have some insight into the business decisions let’s take a look at the employer requirements and then the indirect consequences of these business decisions for employers and SDS management.
In electronic systems there is often additional data (like quantities or locations) beyond the just an MSDS or SDS with any record – so when 3 SDSs become 1 – if the single new SDS is uploaded – which record should remain – or do all 3 get updated causing triplicate costs for what is now one SDS. If you are managing in binders – did you look enough to catch the MSDSs if the other products are being used that should now be archived?
Similarly – when 1 MSDS becomes 10 SDSs – in an electronic system – where all that was tracked was all 10 names – which SDS is applicable – you don’t want to manage and pay for all 10 if you don’t need to. And again – there is that facility data.
These challenges lead to some questions -
SiteHawk has had a front row seat to the MSDS to SDS transition as a SDS management software and services provider. We have a collection of SDSs from thousands of global clients across a broad range of industries that allows us a unique perspective on SDSs. From this information we can give some insight into the GHS status of SDSs as a whole.
Birds Eye view of transition from MSDSs to SDSs Post OSHA 2012 adoption. Overall I would say this is very good. Updating SDSs is not an easy task.
Are 100% of SDSs GHS compliant – well not yet – but close.
And in speaking to the 90% - keep in mind this is a global sampling of SDSs – and some jurisdictions (like Canada) have not reach their transition date for mandatory compliance. Also, something else to consider, old products that have been discontinued aren’t required to have an updated SDS that includes GHS information. So really technically 100% of documents aren’t going to include GHS information and I am not sure they will for quite some time if ever.
How do you transition when MSDS documents don’t clearly line up with the SDS documents that should replace them?
Here was have data from a case study on 2 facilities in the same company that each took a different approach to the transition -
Facility A – conducted a physical inventory that captured the label information for all materials at their facility. The label information from the inventory was used to contact vendors to actively obtain new SDSs for all materials on the inventory and then old documents were archived. This whole process, inventory, requesting SDSs and archiving old documents effectively reset their SDS records and got rid of old documents. It shored up the scenarios where 3 became 1 and identified where the 1 became 10 and which of the 10 are used (and also where they are used). This process ultimately results in a much higher percentage of GHS SDSs and very few documents that were older than 5/1/2012 (the effective date of OSHA HCS 2012).
Facility B – had no physical inventory; Relied more on organic document management and the versions lining up and a 3rd party service being able to update their SDSs for them. As a result there was a much larger percentage of SDSs with revision dates prior to when OSHA 2012 went into effect and also much fewer SDSs that had GHS information.
Well facility A’s percentage doesn’t really seem all that high. Well to make a determination of facility A’s progress it it really best to compare their % of GHSs to a much larger sample of SDSs – Say the SiteHawk catalog. In looking at the date ranges in the bottom 2 charts - the majority of their SDSs were newer than 5/1/2012 – so let’s compare their percentage of GHSs to the catalog from that date range to see how they compare.
Q: Why are all of our documents not GHS - are vendors not updating their SDSs?
A: They are updating their documents to be SDSs – but because of the business decisions vendors made the revised documents don’t always have a 1:1 relationship.
In addition - materials discontinued prior to June 1, 2015 = SDS not required - if a material was not manufactured after June 1, 2015 the manufacturer has no obligation to update to an SDS.
Documents are separate from the product - and when you think in terms of OSHA regulations that the SDS must match the label it could be difficult to find a true match that is the SDS for a product at a facility.
Q: This material we have used for years now has several hazards that we did not see before – what is going on?
A: With the adoption of GHS there were several hazards that were added new and several (mutagen and reproductive) that had significant changes to the thresholds that determine material classifications.
Q: It has Safety Data Sheet at the top of the document does that mean it’s updated?
A: No
Q: I have 3 vendor SDSs for nitric acid – but they all have different information in section 2?
Another thing that is common after adoption of GHS is that the same substance may have different classifications. At the same presentation referred to initially the global chemical manufacturer also compared 17 different supplier SDSs for 50-70% nitric acid. They found 17 different sets of classifications. Not only is GHS adoption not harmonized across regulatory bodies that have adopted GHS – classifications for substances can’t be expected to be consistent across vendors – there is professional judgement that goes into determining the classifications – which contributes to this lack of harmonization.
Conduct a physical inventory. A physical inventory can be used to effectively reset your SDS records. In conducting an inventory here are some best practices from our inventory team –
Tidy Up - For safety and efficiency purposes, do a little "spring cleaning" on the areas that you are going to inventory. Dispose of unused or outdated chemicals before beginning.
Label or bar code materials - Make sure all chemicals are labeled or use bar codes, if they’re available from your SDS or inventory management system. Labeled materials will speed up the inventory process and allow for the least disruptions of production lines or research activity
Plan the work, work the plan - Set the date early and educate employees about the inventory process. Have a map of the facility and, if employing multiple teams to inventory, assign areas up front so there is no overlap or redundancy in effort.
Create chemical areas – If you don’t already have them. Doing so will allow you to organize your inventory by these chemical areas. Areas can either be the physical location or logical grouping of materials. Typically, this is by physical location, such as "Store Room II-B," but sometimes it is also by a logical department, such as "Maintenance." If using logical areas, try to organize the individual physical locations within the department, such as "Maintenance -- South Building."
Be thorough - Do not skip chemical areas, cabinets, etc. and proceed in a planned, organized fashion.
Be detailed - include the entire product name, manufacturer, product code, container, physical form, and quantities. Furthermore, don't move misplaced materials during the inventory. Make a note and move them to their proper location later.
Audit as you go - Have other individuals or separate teams perform spot checks throughout the day, rather than after you're done. This way, any issue in the inventory process or counts can be addressed while the inventory is in process.
Consider an inventory software
Develop a routine inventory schedule - Finally, make the chemical inventory process a routine event, perhaps annually. If this becomes burdensome, consider hiring a professional to perform the inventory. They will have access to the best tools and techniques to get the job done most efficiently and relieve you and your team of the inventory chore.
For more information on these inventory tips – I have a sign up sheet in the room where you can provide your contact info and we’ll send you your own copy for free. If you decide later you need a copy of the white paper I have also included how to access the White paper online in the references section.
Don’t just do an inventory. Be sure to plan for more than that
Consider who is going to do the work to action the inventory. If using a 3rd party - ask is the cost to true up the physical inventory to the documents included, if not what is the cost so that it can be allowed for in the budget. Otherwise the inventory will not achieve the ultimate goal and will be a waste of time and resources. Be sure that the information will and can be used to true up hard copy binders or electronic system otherwise the inventory will be a wasted effort.
Use the information to reach out to vendors to obtain GHS SDSs for products
Acquire SDSs for products that you may not already have SDSs on file for
Archive will get GHS percentages up
2. Know how SDSs are coming in; have a process to manage these and get them where they need to go regardless of the method that they are transmitted or who at a facility receives them.
3. If you don’t do an inventory review your SDS records for versions of MSDSs that have really been replaced with SDSs but maybe they did not line up 1:1 (because of the business decisions that were made during the SDS update process).
Review your SDSs for newly identified hazards that need to be part of your training programs. If you have an electronic system that allows the hazards of the materials used to be tracked – see about getting reports on those hazards.
4. Be at least familiar with GHS or OSHA HazCom as a reference – suppliers don’t always author compliant SDSs. Be prepared to review SDSs and ask questions when things don’t line up or inconsistencies are noted so you can ensure your people are protected. Review incoming SDSs – the hazards may have changed. These will need to be known so that employees can be trained and appropriate precautions, if needed, can be taken.
Keep on working; don’t give up – we are still riding the tail end of the wave that was a revolution in hazard communication. The work is not over yet. Monitor for changes to regulations & get involved
Looking ahead –
GHS will continue to be revised every 2 years. So revisions to regulations at varying intervals are to be expected. Frequency of revisions to be determined by various jurisdictions legislative process.
OSHA is starting rule making process to revise HazCom Standard. OSHA’s initial adoption included UN GHS Rev. 3.
In the meeting to start the process to revise the standard OSHA indicated they would be considering all changes through UN GHS Rev. 6. In the resources there is a link to the regulatory agenda item that tracks the rule progress.
