The five substances are the following, along with the proposed harmonized C&L:

Isoxaflutole: Addition of an acute M-factor of 10; Addition of a chronic M-factor of 100.

Tembotrione: Skin sensitization; Specific target organ toxicity – repeated exposure; Hazardous to the aquatic environment.

Metosulam: Carcinogenicity; Specific target organ toxicity – repeated exposure; Hazardous to the aquatic environment

Potassium sorbate: Skin irritation; Serious eye irritation.

Tetrakis(2,6-dimethylphenyl)-m-phenylene biphosphate: Removal of Aquatic chronic 4.

The ECHA press release includes additional information on these substances, such as EC number, CAS number, and examples of uses.

The public consultation period will last 45 days. Comments can be made until June 28, 2012 by using a web form on the ECHA website, and will be considered by ECHA’s Committee for Risk Assessment (RAC). The Commission takes into account the RAC’s opinion when it decides whether a proposal for harmonized C&L is accepted. If so, the substance is added to the list of hazardous substances for which harmonized C&L has been established (Annex VI, part 3 of the CLP Regulation).

If you create EU SDSs, either through software or services, for any of the five substances or for mixtures that contain any of the five substances, you may have to update your affected SDSs at some point in the future, based on whether the new proposals for harmonized C&L are accepted.

Given the complexities associated with managing formulations, software exists specifically for that purpose. Most companies that have MSDS authoring software also have separate software to manage formulations. This software can be a standalone formulation or recipe management system, or an ERP that contains multi-layer composition data for products such as SAP EHS Management . Some companies, especially in the EU, may use IUCLID5, the software made available by ECHA for the purpose of submitting REACH-related data, as their de facto formulation management system. It is also worth noting that in some instances, companies may not have a separate formulation system and may use their MSDS authoring software as their de facto formulation management system as well.

Since composition information is very important for the creation of (M)SDSs, and since the information is present in another system, companies must make sure that the information is synchronized to avoid any discrepancies and risks of inaccurate and non-compliant (M)SDSs. The form that this synchronization will take depends on such factors as the IT architectures of the formulation system and the MSDS authoring software, costs, and more importantly the frequency of formulation changes. If formulations change often, it may be a good idea to have some form of automated interface between the two systems, where changes in the formulation system will automatically lead to changes in the MSDS authoring system. If formulations change rarely, an import file can be used to update the MSDS authoring system with data from the formulation system. If your situation is somewhere in-between, then you can run an import script each time there are changes in the formulation system, or at frequent intervals. Finally, synchronization is not necessary if the formulation management function and the MSDS authoring function are performed by a single integrated system used for EHS management or product compliance.

An obvious factor influencing the cost is the number of jurisdictions and languages for which MSDSs are required. If for a given set of products, MSDSs are required for 5 jurisdictions (e.g. U.S., EU, Japan, etc.), the cost is impacted exponentially. This is especially the case when language translations are brought in the picture, for example the same SDS for the EU being required in 8 EU languages, or MSDSs for countries with more than one official language (e.g. Canada, Belgium, Switzerland, etc.).

Jurisdictions and languages are not alone in influencing costs. An overlooked aspect is the complexity of the products. Authoring an MSDS for a pure substance already classified takes much less time than authoring an MSDS for a complex mixture with many raw materials that are themselves mixtures, especially if there is not a lot of information available on the raw materials. In this case, the author has to consult individual MSDSs of the constituent raw materials, or inquire more about test results on the finished product, if available. This contrasts with authoring an MSDS for a pure substance that is present on many regulatory lists, and for which classification for various hazards is already known. The vendor probably already has such an MSDS, and all they have to do is put the appropriate branding and company information on it.

Other factors that may also impact costs include OEM/private branding requirements, e.g. the same MSDS for the same product being created in multiple versions, one for each business unit of a company. The costs can also be impacted if heavy customization and tailoring are required because your own standards or industry-specific standards have to be applied. Finally, costs can increase if you need associated documents, such as labels, Workplace Safety Cards, summary sheets and Exposure Scenario annexes for EU REACH SDSs.

Since laws and regulations change, your MSDSs will also change. MSDS creation software that allows you to locate MSDSs corresponding to a criterion with just a few clicks can be greatly helpful. A number of examples illustrate this. If a substance has been added to a regulatory list, like the REACH SVHC list, you want to pull all the MSDSs of your mixtures that include the substance. Similarly if a raw material has new REACH exposure scenario information, you want to pull all the MSDSs of your mixtures that include the raw material. This type of “where-used” functionality has tremendous value. Another example is if the regulation changes regarding products classified in a certain way. In this case you want to pull all the MSDSs of your products that are classified in that way. It is important that “where-used” or query and reporting functionality be easy to use and require only a few clicks.

Another overlooked feature is the audit of rules. Many MSDS creation software have rules or algorithms to automate product classification and the determination of statements on the MSDS. You may be asked to explain why a certain output is being produced on the MSDS. Audit functionality will show you how the rules reached the result that is displayed. Some MSDS creation software vendors also offer full documentation of their rules by explaining the input, the processing logic and the output. This type of documentation can help you better understand the behavior of your MSDS creation software.

There are a couple of other features of MSDS creation software worth mentioning. Since there can be multiple MSDSs associated to a single product, MSDS creation software should be product-centric, meaning it distinguishes the products and their MSDSs. This way you can perform a change once to your product and re-create all the MSDSs simultaneously for that product. In addition, some MSDS creation software offer helpful wizard-type functionality, where the user is guided step-by-step through the process of creating the MSDS. This type of functionality can also save you a lot of time and improve the ease-of-use of the MSDS creation software.

• Installation. Some MSDS software programs are relatively easy to install on a PC or a server and scale well. But others can consume a significant amount of time of your IT department, or your system integrator. This further adds to the total costs of the software. It is also important to know the disc space that is required, to assess if additional hard drives or servers have to be bought, which would further add to the costs.

• Upgrades. Since laws and regulations change frequently, the regulatory content feeding the MSDS software program also changes. Upgrading the software can be costly if there is no ability to update the regulatory content independently, without installing a new version of the software or affecting severely the existing installation. You must be aware of the way software upgrades take place to have a better idea of the total cost of ownership.

• Integration with other systems. MSDS software programs may require integration points with ERPs or other systems to bring product data into the MSDS software, or send the MSDSs to an external document management system. The time and costs associated with establishing these integration points, and maintaining them with each new version of the MSDS software, the ERP or the other systems, must be taken into account.

There are other elements adding to the total costs of MSDS software programs, such as user training, data migration and others, but being aware of the items mentioned above will help you avoid nasty surprises in the medium-term and the long-term.

The first option is software-based. Under this approach, you acquire MSDS authoring software and you create your MSDSs yourself. The advantage of this approach is that you have full control over your MSDS authoring. You can create and edit your MSDSs whenever you want to and in any way. However with great freedom also comes great responsibility. If you handle yourself all your MSDS authoring, you need to make sure that you have people who know how to author MSDSs. You must also have the in-house regulatory expertise to know whether and when MSDSs need to be changed. Finally, if you go with the software approach, you need to make sure that you evaluate diligently all the vendors that offer MSDS authoring software, and assess whether the regulatory content offered with the software has enough breadth and depth; and whether the software acquisition, installation and upgrade costs are appropriate for your budget.

If the software approach is problematic for you, there is always the services-based approach for MSDS authoring. Under this approach, your MSDS authoring is outsourced to a vendor that authors your MSDSs for you. The advantage of this approach is that you do not have to worry whether you have the in-house knowledge to author MSDSs and track regulations. Everything is taken care of, including language translations. Some vendors that offer MSDS authoring services, also offer a service where they will “maintain” your MSDSs for you. If regulations change, which requires changes to your MSDSs, they will inform you and pro-actively edit your MSDSs, thus further alleviating a regulatory burden for you. However if your product compositions change, it is your responsibility to inform the vendor. The disadvantage of the services approach is that you do not have full control over the process. If, for example, you want to perform a very minor change to an existing MSDS, you have to go to the external vendor. To get around this and other concerns, some vendors offer a hybrid approach where they create the MSDSs initially for you, and then upload the product data and the MSDSs into your MSDS authoring software. This way you can edit your own MSDSs, while still relying on the vendor to re-author MSDSs if there are major regulatory changes, or author new ones for new products.

On March 20th, after a long wait, the US Department of Labor filed the Final Rule updating the Hazard Communication Standard (HCS) at the Office of the Federal Register, which will publish it today March 26, 2012. In this Final Rule, OSHA is modifying its HCS to conform to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The effective date of the Final Rule is 60 days after today’s date of publication.

The adoption of GHS by the US was already expected, and the only points that remained to be clarified were the timing of the adoption, and the effective dates for the implementation of GHS with regards to MSDSs (known as “SDS” under GHS) and labels. The OSHA website provides a lot of information and explains very well the effective dates that chemical users as well as chemical manufacturers, importers and distributors have to abide by. Here are the important dates to remember:

December 1, 2013: Companies must train their employees on the new GHS label elements and SDS format before this date.

June 1, 2015: As of this date, companies must comply with all modified provisions of the Final Rule, meaning all labels and MSDSs must conform to the US implementation of GHS. There is one exception to this: Distributors may ship products labeled by manufacturers under the old system up to, but not including, December 1, 2015. It is worth noting that June 1, 2015 is also the date as of which GHS (known as the CLP regulation) is fully mandatory in the EU.

June 1, 2016: Companies must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Great flexibility is provided for the transition period between the effective date of the Final Rule (60 days after today), and June 1, 2015 as of which all labels and MSDSs must conform to GHS. During this transition period, companies can comply with the current standard, the new GHS standard, or both. No distinction is made between substances and mixtures, unlike other countries where different effective dates were provided for each. For example, in the EU both GHS and the old standard have been used simultaneously for substances since December 1, 2010, while GHS will be mandatory for mixtures only as of June 1, 2015, even though companies are allowed to use it now alongside the old standard. It remains to be seen whether the lack of different effective dates in the US between substances and mixtures will be problematic, since the GHS classification of substances can contribute to the GHS classification of mixtures, therefore the former may be needed for the latter.

Follow the latest developments on MSDScompliance.com to learn more about GHS implementation in the US and around the world, and its impacts. You can also learn more about the Solution Providers that can help you with GHS compliance.

Most people are aware about the importance of MSDSs, whether from a compliance perspective, or an employee safety perspective. Yet despite this importance, there are people who still treat the MSDS like any other document. They assume that managing MSDSs through a simple and basic file sharing or document management system is enough. This assumption is wrong and can have negative consequences. The use of MSDS management software from a solution provider is the right way to handle your MSDS management needs for a number of reasons. Let’s clarify first what we mean by MSDS management software. There are three types of MSDSs that MSDS management software is used for: MSDSs of raw materials that you purchase (e.g. solvent to include in your paint), MSDSs of products that you use as part of your production process (e.g. grease or oil for your machines or tools), and MSDSs of your own finished products. Here are some of the reasons to consider the use of MSDS management software:

• Many vendors, in addition to offering MSDS management software, may also offer a service to get MSDSs from your suppliers on your behalf. This ensures that you always have the latest version of the MSDSs in the system. The MSDS management software will have the mechanisms in place to allow you to request updates to MSDSs, or for MSDSs to be updated automatically whenever suppliers issue new versions.

• MSDS management software helps manage not just the documents, but also the location of chemicals throughout a company. MSDS management software can help locate the presence of chemicals in a hierarchical way (shelf, room, plant, factory, location, city, state, country, business unit, etc.) and produce consolidated views on the locations of chemicals. This can be achieved in a much more flexible and user-friendly way compared to a basic file sharing or document management system.

• MSDS management software often includes features that use the data present on the MSDSs of chemical products to perform searches, queries and reports. These features can save you a lot of time, and contribute to product compliance assessments on your raw materials and manufactured products.

• MSDS management software can do more than basic document management. It can include other important functions such as inventory management, automated request and approval process for chemicals, label creation, integration to a corporate website to give your customers online access to MSDSs, and automated distribution of MSDSs by e-mail to your customers. It can also connect to ERPs or other external systems to support additional business processes.

Find top software vendors in a single location for MSDS management software

GHS is forcing companies to assess the way they author their MSDSs because many MSDSs will have to be re-authored to be in line with GHS. Naturally people seek software-based solutions to address the challenges of implementing GHS. This has given rise to the term “GHS software”, which really is another way of defining MSDS authoring software that supports GHS. How do we define GHS software, or whether MSDS authoring software supports GHS?
In essence GHS software will help you create GHS-compliant labels and GHS-compliant MSDSs. But what does that mean? GHS defines hazard classes, and defines the categories of each hazard class by specifying what triggers the categories. GHS software will automatically calculate GHS classifications based on product data and product composition. The result will be GHS-defined Hazard and Precautionary statements on MSDSs and labels, as well as GHS-defined pictograms, replacing the former statements and pictograms of countries that have adopted GHS. Some GHS software will also integrate regulatory lists of various countries with GHS classifications for substances, thus further automating the process of determining GHS classifications for products.

Now that we have defined what GHS software is, are there some additional characteristics that we should also take into account? There are two. First, some countries that have recently adopted GHS, or are about to, have transition periods where the old system is still applicable in addition to GHS. The transition periods may vary based on substances, mixtures and whether substances or mixtures are already in stock (and therefore labeled) or not. As a result, some GHS software will allow you to continue using the old system in parallel to GHS. Second, a common misconception is that GHS is a global regulation from the UN applying to every country. It is not. GHS is a framework, or a model regulation, that individual countries can adopt as per their own timeframe and with their own transition periods. But more importantly, countries can choose which categories to adopt for the various GHS hazards. This creates a situation where, while the definitions of hazards and categories are the same, GHS implementation can vary by country. For example, for a given hazard, one country may implement all 4 categories, while another country may implement only 3 and not implement the least severe category. This is referred to in the industry as the “building bloc” approach. It is important for GHS software to support the country-specific implementations of GHS, in addition to the model framework.

Search through our extensive list of GHS Software providers for MSDS/SDS Authoring by visiting the software search page and click “GHS Solutions” then click Search. Get Started now.

When you are looking for MSDS software, it is important to know what type of MSDS software is needed and for what business processes. Just as “EHS software” can mean many things, MSDS software can also mean many things and can include different features. Here is a very simple and helpful categorization of MSDS software:

• MSDS management: This category of MSDS software helps you manage: MSDSs of raw materials that you purchase (e.g. solvent to include in your paint), MSDSs of products that you use as part of your production process (e.g. grease or oil for your machines or tools), and MSDSs of your own finished products. There are three things to note about this type of MSDS software: 1) Many vendors, in addition to offering the platform to help you manage the MSDSs, also may offer a service to get MSDSs from your suppliers on your behalf. This ensures that you always have the latest version of the MSDSs in the system. 2) Vendors can offer the software either as a standalone product that you purchase and install on a PC or server, or as an online application that you log into. 3) Some MSDS management software also include additional features, such as automated distribution of MSDSs by e-mail to your customers, search capabilities, and reports. The features often can save you a lot of time, and contribute to product compliance assessments.

• MSDS authoring. This category of MSDS software helps you create your own MSDSs for the products that you manufacture. MSDSs of your products must be provided to your clients. MSDS authoring software includes the actual application and the regulatory content required to create MSDSs. Content includes rules to automate product classifications and the determination of statements on the MSDS, phrases in multiple language translations, regulatory lists, and MSDS templates for various jurisdictions around the world.

When purchasing MSDS software, it is important to look at the big picture and to evaluate all your needs, not just the latest that is creating the most noise. You may need today software with regulatory content to re-author your MSDSs and make them compliant with GHS. But later you may need an automated system to assess the compliance status of your raw materials based on the information included on the MSDSs from your suppliers. It is better to look at all your MSDS software needs, current, future and potential, and save costs and time by purchasing a system that meets all your needs.

To see a list of the major MSDS software vendors, visit MSDS Compliance and click “Search Software”. There you will have the ability to view, contact and compare top rated MSDS vendors.

-MSDScompliance Team