The deadline for GHS conversion in the United States and European chemical markets has passed, but some companies have not made the transition yet. If youre in this position, dont worry – theres still hope. Even though both the U.S. Safety Data Sheet and European Union classification, labeling and packaging regulations officially became the standard for chemical reporting on June 1 of this year, you should be able to avoid serious trouble as long as you complete the conversion process within a year or so.
Legal requirements to change over to the new systems are definitely a pressing reason to convert, but downstream user demand can be equally as stressful. We work with a lot of companies who figured that they would just convert their MSDSs to SDSs as necessary after the deadline. This strategy is not a great recipe for success because if you fail to account for the time it takes to convert, your customers will likely be unhappy with the wait.
GHS Primer
If you are so behind on conversion that you dont even know what you are supposed to be converting, lets review. The Globally Harmonized System of Classification and Labeling of Chemicals, adopted in 2012, created a new system of chemical hazard reporting. United Nation member countries worldwide agreed to create national systems mirroring the GHS, meaning that material safety data sheets needed to be scrapped in favor of safety data sheets.
The main difference between SDSs and MSDSs comes in Section 2 of the new safety data sheets. This section is not entirely new, and manufacturers will usually retain about 30 percent of their original hazard warnings. The other 70 percent features new hazard classifications and accompanying symbols, intended to create a standard international way to transmit warnings to end users. These warnings and symbols also need to be displayed prominently on the chemicals storage labels, so youll need to create GHS labels in tandem with new SDSs.
No one needs to create SDSs for any specific chemical except the manufacturer and refiner. If you are a user at any other point on the chain, all you need to do to convert your database of MSDSs is request them from your suppliers. But if you are a manufacturer or refiner, you should start the conversion process as soon as possible.
Software Can Help
Some companies immediately turn to SDS conversion software, intending to get the conversion done as quickly as possible in-house. Again, planning ahead is a crucial part of good SDS-related service.
The process of choosing software should not be rushed. Most SDS conversion software runs upwards of U.S. $30,000, and the cheaper ones cannot provide a comparable user experience. Because youll be relying so heavily on this software to help meet standards, it is important not to rush the process and end up with software that wont fit your needs.
When choosing software, try to obtain a demonstration copy first to check out how it feels. Each SDS requires quite a bit of data entry, so you will want to choose software that makes this as easy as possible. You will also want to look specifically at what the software company can offer to help meet your companys needs. For example, even though we are a primarily U.S.-based company, Quantums SDS software includes an EU SDS generation module and translations into over 30 languages.
Once youve chosen software, generation is fairly easy. Creating SDSs on demand, therefore, becomes a reasonable expectation because the conversion time is spent mostly on data entry. Opting to use software instead of a conversion service also affords the ability to author entirely new SDSs just from formulas and properties, whereas SDS conversion services charge higher rates for this process than they do for a simple conversion from an MSDS to a SDS.
Implementing software takes time on its own, however, and is really only recommended for manufacturers that have several hundred MSDSs to convert. If you need to convert only a few MSDSs, conversion services are probably a better bet.
Outsourcing
Choosing to outsource conversion seems stressful for some companies because they need to share some trade secrets to display accurate information on the final SDS. These worries can be allayed by choosing a provider carefully. Any reliable conversion service will sign a nondisclosure agreement and display only selected information on the final SDS.
Conversion services are usually billed on a per-MSDS basis. Some companies add extra charges like consultation fees just for reviewing MSDSs, so always check carefully for hidden costs within the initial quote.
Because you will have to trust these companies with sensitive information, be wary of ones that try to sneak extra things into their contracts. Reputation is important; an established company is generally more reliable than a
new one. It is harder to trust that the chemical database of a newer company is accurate because it has not been validated over time.
Once you have submitted all your information, the conversion typically takes a few days to a few weeks, depending on how many MSDSs must be converted. If you are feeling high pressure to deliver, you can usually pay a rush fee to have the conversions made and sent to customers within a day or two.
Outsourcing is definitely a longer process than conversion through in-house software. But the overall cost is often lower.
Dont Do It by Hand
Some manufacturers may be tempted to attempt the conversion by hand. This is not recommended because the process used to determine hazard classifications is pretty complex. And regulatory agencies have promised to enforce incorrect or missing GHS SDSs on a per-SDS basis rather than with a flat fee.
Even if you are certain that your calculations will be correct, the time it takes to convert each MSDS is incredibly cumbersome. According to U.S. Occupational Safety and Health Administration estimates, it takes over 5 hours to convert an SDS by hand. These times likely differ across nations, but conversion is always an arduous process. If you have time and manpower to devote to GHS training and conversion, you can generate SDSs by hand. However, if you do not have the time or personnel, converting by hand is probably a bad idea.
The Final Analysis
Once youve chosen the direction to take for SDS conversion, your path to full compliance should be simple. Dont worry too much about labels as a separate entity; your conversion provider or software should be able to set these up easily. You also should have already trained your employees to understand the GHS hazard classification system, so integrating the new SDSs and labels into existing warehouses and databases should be quick and easy.
Any operation that lags behind an internationally assigned deadline is certainly stressful, and customer pressure doesnt help. You and other manufacturers are subject to some serious fines if you dont produce new GHS-compliant SDSs in the near future. But even with the rush, its still important to exercise care in choosing the kind of service you want and the provider of that service.
SDSs and labels with inaccurate hazard classifications lead to serious harm; therefore, choosing an inexperienced provider can hurt you more than taking too long to begin the process. Whether you convert using a software service or outsource the process, using an established and trustworthy company that can help you convert efficiently and accurately will be the most important factor in keeping your employees safe and your business compliant with the regulations.
Yiwei Chen is managing director at Quantum Compliance, based in Ann Arbor, Michigan, United States. Contact her at 1-734-930-0009 or yiwei.chen@usequantum.com.