As a new order for classifications and label text is begun, the song “Time Is On My Side” by The Rolling Stones comes to my mind. Take a listen here to remind yourself of the rhythm and lyrics. I and many other SDS and Label authors approach each new request with optimism and the hope that a perfect world exists. Believing all of the information needed is supplied by the client, the data needed is readily available and the time needed for work is plentiful.
For any given order there could be multiple products and each product requires an SDS and Label. Each of the products is probably a mixture. In some cases the products are actually mixtures made up of other mixtures. Some of the products have trade secret claims. Taken together, this means we authors start to question what Mick Jagger is saying. Is time really on my side?
Now, clients are amazing. Any information needed requires a simple email or phone call. If they have it, then within a short period of time it is provided.
Things start to fall apart though when information just is not there. Many companies are still struggling with receiving SDS and Labels that are compliant with HazCom 2012 from their manufacturers and suppliers. When this happens, I am tasked with finding information on my own. This finding of information is the Continue Reading…
Where’s the Beef?
A better question to ask than the one posed in the title is “Where’s the beef?” Many will remember this 1980’s catchphrase uttered by Clara Peller in an advertisement for the fast food chain Wendy’s. The purpose of this advertisement was to differentiate between the big name sandwiches provided by McDonald’s and Burger King and Wendy’s own Single. The difference was in the size of the bun used by the competitors and the large beef patty used at Wendy’s. (Click here for the Wendy’s Commercial)
For those in the hazard communication industry, the question applies because of the June 1st deadline. This deadline was for all safety data sheets (SDS) and labels to be updated under the new OSHA HazCom2012 format. It is now after July 1st and many downstream users are asking “Where are the updated SDS and labels” much like in the Wendy’s commercial. Granted some companies made the deadline and are supplying the new versions of the documents. Unfortunately, there are a great many that have not.
So, are things really different?
Many on the business side of manufacturers, importers and distributors, the answer will likely be, “not much”. The business is still manufacturing product, importing goods and distributing items. That process has not truly changed. From a Regulatory or Compliance point of view the answer to that is “yes”. If your company has not Continue Reading…
The Next Revolutionary War?
For many, this transition period to OSHA HazCom 2012 from the Hazard Communication Standard of 1994 can best be summarized by Thomas Paine’s famous quote, “These are the times that try men’s souls.” While it was used in the pamphlet The American Crisis to deliver the ideas of the Revolution to the people of early America, there are many in the throes of classifying chemicals, substances and mixtures that feel this quote applies to daily life.
There is pressure on SDS authors, either internally or externally, to “get it right”. How can we be sure our classification is accurate? Did we cover all the hazards? Did we use the correct data? Should we check other sources? These last two questions can be the most difficult to answer.
To be a “good” SDS writer, never stop at just one source of data. Since OSHA chose not to use the exact language out of GHS Revision 3 and only selected certain building blocks when developing HazCom2012, care should be taken when utilizing classifications from other world areas. One has to remember that many other world areas did the same thing. Using classifications derived under another country’s system could lead to some over-classification, or under, depending on which country’s system is used.
A prime example of this would be Toluene. A straightforward colorless, insoluble, liquid chemical used mostly as a solvent, Continue Reading…
The Time Has Come!
I’m late! I’m late! For a very important date!” No truer words are spoken than by the White Rabbit in Lewis Carroll’s story and the 1951 Disney movie “Alice in Wonderland”. The rapidly approaching deadline of June 1, 2015 will be here sooner than people think, given it is currently the beginning of March. It is on this date that “everyone” must be in compliance with all modified provisions of the Hazard Communication Standard (HCS) or what is more affectionately known as HazCom2012. What has everyone in “White Rabbit Mode” is the lack of classifications or Safety Data Sheets (SDS) from suppliers that would enable classifications of everyone’s in-house products.
Upon the release of the new standard back in 2012 it was stated that all chemical manufacturers, importers, distributors, and employers must be in compliance with the new standard no later than June 1, 2015. For many, panic struck upon the realization that the needed information for classifications would not be available since everyone would be on the same time schedule. This feeling of panic can be likened to meeting having tea with the Mad Hatter.
OSHA’s Enforcement Guidance
On February 9, 2015, OSHA released a memorandum on the topic of Enforcement Guidance for the upcoming June 1st deadline. In this memo, there is a chance for some breathing room and relief. The memo, which can be read here, Continue Reading…
David Bowie’s 1971 album “Hunky Dory” included the song “Changes” which was released in January 1972. While being recognized as one of Bowie’s most well-known songs, it never made it in into the “Top 40”. One of the lyrics from that song is
“Ch-ch-ch-ch-Changes / (Turn and face the strain) Ch-ch-Changes”.
Those lyrics are most appropriate given the release of the UN ECE Secretariat’s publication of the changes to the 5th Revised edition, which will lead to the creation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Sixth Revised Edition.
Here is the link to published changes document.
Six of the changes coming to Revision 6 are as follows:
- Desensitized Explosives. A new hazard class for Revision 6 which carries the definition of “solid or liquid explosive substances or mixtures which are phlegmatized to suppress their explosive properties in such a manner that they do not mass explode and do not burn too rapidly and therefore may be exempted from the hazard class “Explosives” (see Chapter 2.1; see also Note 2 to paragraph 184.108.40.206).” This new class will have four categories and include its own label elements, H phrases and P phrases.
- Pyrophoric Gases. Chapter 2.2 entitled “Flammable Gases (Including Chemically Unstable Gases) is changing to “Flammable Gases”. While the title change is not necessarily newsworthy, the inclusion of the hazard class pyrophoric gases” is. This hazard class now Continue Reading…
Which way do I go, George?
John Steinbeck’s novella “Of Mice and Men” is often a required reading for many school children. Though published in 1937 about a story of migrant workers in the Great Depression, it has many themes that are still powerful today. What many don’t know is that one of Steinbeck’s characters from this story is parodied in a classic Looney Tunes cartoon.
Of Fox and Hounds
In this cartoon, Willoughby the dog is fooled by George the fox. Willoughby is voiced by Tex Avery, while George’s voice is done by Mel Blanc.
Now what does this have to do with Safety Data Sheets or SDS? Often when tasked with writing a SDS one can feel like poor Willoughby. All of the information is available, but which way do you go. Which way do you go?
ICC Compliance Center can help and it won’t be in the way of George in the cartoon. We offer five different SDS Services.
But how do I choose which is right for me?
- SDS Creation: The process is simple. Send us a basic product information sheet, the raw materials SDS documents, and the countries involved and we can write an SDS for you that meets the requirements of OSHA HazCom 2012, WHMIS, European REACH, or European CLP. We even offer to sign a non-disclosure agreement to keep your product information private.
- SDS Reformats and Revisions: Most companies already Continue Reading…
Remember eating alphabet soup as a child? Remember playing with the noodle letters to make more words than your friends or siblings? Remember when the letters would not cooperate and random letters were floating in your bowl? Remember trying to use abbreviations and acronyms to make those random letters work? Oh, the frustration! Working on Safety Data Sheet (SDS) documents in the European Union (EU) can often feel like some of those memories.
ICC Compliance Center is here to help and possibly give some new ways to win in your next competition.
EU – Directives and Regulations
As a reminder, the EU governs hazard communication in two ways – by directives and regulations. Directives mean all member states are required to implement their version of the directive within their state. Regulations, however, mean complete implementation in all member states without the need for or allowance of versions in each state.
Current directives and regulations
As of February 2015, there are multiple active directives and regulations at work in the EU. The oldest is the Dangerous Substances Directive (67/548/EEC) or the DSD and the Dangerous Preparations Directive (1999/45/EC) which is the DPD. This is followed by the Registration, Evaluation, Authorization and Restriction of Chemical Substances Regulation more commonly known as REACH (EC1907/2006). Finally, there is the Regulation on Classifying, Labeling and Packaging of Substances and Mixtures (1272/2008/EU) or in the shortened form the CLP. It should be mentioned Continue Reading…
After a few recent inquiries regarding reliability of information on MSDS (material safety data sheets), I began to reflect on the various ways that MSDS are used and abused. Having been around during the introduction of standardized MSDS in Canada and still being here (!) for their next incarnation as “SDS” (safety data sheets – the GHS version expected under “WHMIS 2.0” and currently defined in US “Hazcom 2012”). It seemed like an appropriate time to consider if we’re likely to avoid some of the confusion that’s been around since the late 80’s.
One of the key points to remember about MSDS-SDS is that, although they may be used for other purposes their primary function in North America has been to provide health and safety information to workers in occupational settings. This is continuing, so far, in the GHS age – the authorities prescribing the content and use of SDS are those responsible for Occupational Health and Safety (i.e. US-OSHA, Health Canada, provincial Ministries of Labour, etc.). Information on other regulatory aspects- environmental, transportation classification, etc. – while provided for, is not mandatory unless these other agencies incorporate MSDS-SDS requirements into their regulations.
Consequently it is risky to unconditionally rely upon the information presented in DG/Hazmat or regulatory (e.g. TSCA/NPRI/DSL, etc.) sections which may be country-specific or out-of-date since the OHS regulations do not consider this information mandatory.
Here at ICC Compliance Center and depending on your application, we may ask you for a CAS number. When we create labels on demand for your exports, among other services, we will ask you to provide us with the chemical name and CAS number and then we are able to provide as few as 100 GHS compliant labels and/or a compliant SDS.
Compliant GHS Chemical Label:
A CAS number or CAS Registry number is a unique identifier for every chemical substance dating back to 1957. The Chemical Abstracts Service (CAS) is the responsible entity that is responsible for assigning a unique number to every chemical described in scientific literature.
A CAS number itself has no meaning. Its primary use is to avoid confusion between chemicals with similar names, or individual chemicals that may have multiple names. It is also used to identify the chemical when a generic or trade name is used.
A CAS Registry Number is separated by hyphens into three parts, the first consisting of up to seven digits, the second consisting of two digits and the third consisting of a single digit.
In short, the CAS number can be particularly useful in database searches because it allows you to search a database and easily pull every record for that particular substance or chemical. For example, “Methanol” is known by multiple names such as methyl alcohol, methyl hydrate, hydroxymethane and Continue Reading…
The Department of the Environment, under the Canadian Environmental Protection Act, 1999 has published an amendment in the Canada Gazette Order 2012-87-03-01, amending the Domestic Substance List. The order adds 14 substances to the Domestic Substances List and modifies the information on one substance.