Automated MSDS Distribution

The new requirements will be a compliance burden for many businesses. Automated distribution is the "Easy Button" for HazCom compliance.

• By Justin Scott
• Oct 01, 2010

MSDS authors, corporate toxicologists, industrial hygienists, and environmental health and safety professionals, take heed: According to OSHA estimates, nearly 1 million Material Safety Data Sheets will have to be re-authored or updated once the new provisions of the Globally Harmonized System (GHS) take effect in the United States. Specifically, according to OSHA research¹, the baseline facts of the Hazard Communication environment are:

• 880,000 hazardous chemicals are used in U.S. workplaces alone
• 5,000,000 workplaces contain chemicals on site
• 40,000,000 workers are affected by the provisions of the Hazard Communication standard (HCS)

So the elephant in the room is, "How are organizations going to efficiently update and distribute nearly 1 million revised safety data sheets to 40 million workers, all in a cost-efficient manner?" Leaving the safety data sheet authoring challenges aside for now, let's focus on the avalanche of documents that is going to bury chemical producers and chemical end users alike in Material Safety Data Sheets (MSDSs) and chemical data.

Communication Requirements for Chemical Manufacturers
In the United States², the manufacturer maintains primary responsibility for disseminating updated chemical information to the chemical end consumer. Chemical manufacturers must ensure appropriate and current material safety data sheets are shared with distributors and employers (chemical end users) with their initial product shipment and any time an MSDS is updated.

Additionally, suppliers should respond to "new and significant" information they receive about a chemical hazard by updating the label and safety data sheet for that chemical. New and significant information is any information that changes the GHS classification of the substance or mixture and leads to a resulting change in the information provided on the label or any information concerning the chemical and appropriate control measures that may affect the MSDS. This could include, for example, new information on the potential adverse chronic health effects of exposure as a result of recently published documentation or test results, even if a change in classification may not yet be triggered. Updating should be carried out promptly -- in fact, in the United States, chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical must revise the MSDS and labels for the chemical within three months of becoming aware of the new information.

Suppliers also should periodically review the information on which the label and safety data sheet for a substance or mixture are based, even if no new and significant information has been provided to them in respect of that substance or mixture. For example, this may require a search of chemical hazard content databases for new information.

Impact of GHS
The Globally Harmonized System will have a significant impact on hazard communication upon OSHA's final adoption of its provisions. The current expectation is there will be a three-year transition period for organizations to adopt the provisions of GHS, including updating safety data sheets and chemical labels, circulating revised chemical safety documents, and training employees on the changes.

The impact to organizations, especially those manufacturing chemicals, is that without efficient processes and business automation, the new requirements will be a compliance burden for many businesses. Similar to unshoveled snow in the middle of a New England winter, the avalanche of updated MSDSs and customer requests for updated MSDSs will bury the unprepared.

The Need for Automating MSDS Distribution
One way to shovel yourself out is to utilize MSDS Distribution technology and services. MSDS Distribution solutions employ business rules for circulating new MSDSs in an existing network for sharing and communicating chemical safety data sheets. Think of it as the digital version of a pack and ship process for hazard communication mailings whereby outgoing messages are automatically triggered based on your business rules, the organization's product shipments, changes in safety data sheets, and your customers' preferences.

Considerations for Streamlining MSDS Distribution
1. Push or Pull. The provisions of OSHA's current Hazard Communication Standard (HCS) maintain it is the chemical supplier's responsibility to supply the required chemical data information in the form of MSDSs and chemical labels to employers. Second, it is the employer's responsibility to provide readily available access to such information to affected employees. Therefore, chemical suppliers must be able to efficiently "push" new and updated chemical safety documents to employers and also support the occasional ad hoc request ("pull") by customers or other end users. It's useful to support both methods, but the main emphasis should be on the right outbound push mechanism and process.

2. Paper or Electronic. Employers have some latitude on how to present chemical safety information to their employees. Some may employ an electronic MSDS management system, while others may continue to use paper-based binders. Your MSDS Distribution approach should consider not only the physical output, but also the preferred customer method of receiving MSDSs, including e-mail, postal mail, or fax. Tying these preferences into the customer records enables an electronic MSDS Distribution system to route the proper documents in the proper media on demand.

3. Frequency and Volume. Do you have one or 1,000 MSDSs to circulate? You also should consider the volume of customers. If you have 1,000 documents and 1,000 customers, you could potentially have 1,000,000 distinct mailing events if every customer required every document in a separate transaction. Obviously, managing this via a manual process becomes more challenging as product and customer counts grow. Furthermore, is this a cost-effective means of utilizing internal resources? Service providers specializing in MSDS Authoring, Distribution, and Management can often perform MSDS publishing and fulfillment for pennies per transaction.

4. Custom vs. Non-proprietary. If your organization builds its own process or system for distributing MSDSs, consider which parts should be custom to your organization and which should be non-proprietary to take advantage of economies of scale. Customer, order, and shipment information are probably closely tied to your business, but perhaps the enabling technologies and business processes for communicating related chemical information are not. In this case, leverage distribution networks that are already in place instead of investing the time and money to reinvent the wheel.

5. Supply Chain Integration. A major benefit that can be realized when considering electronic MSDS Distribution options is the ability to integrate supply chain systems and MSDS authoring systems to your distribution platform. In this case, automated workflow manages the entire process from revision alert to MSDS authoring to MSDS publishing or from chemical shipment to MSDS publishing. Closing the loop offers a "hands free" utopia of chemical data information publishing.

Technology in Action
Technology is not always the answer, but as it relates to MSDS Distribution, there are definite economic and "peace of mind" advantages to employing the right technology and service solution. I say technology and service because the right solution utilizes both, because this is an integral element of your overall customer service and support strategy.

First, the business rules are defined to account for the considerations discussed above. The electronic MSDS Distribution platform can be set up to account for variable methods of delivery, frequency, shipping information, document cross-referencing, document revision triggers, and individual contact preferences, among other variables. The distribution system should maintain this business logic, as well as other circulation parameters, such as delivery history and default actions for periods of no activity or scheduled updates of the MSDS.

Once those options are set, it can be a push-button operation via the MSDS Distribution platform. A feed of daily/weekly/monthly product shipments is required and fed to the distribution system, which then processes the feed using the business rules established above, as well as stored knowledge of the customer, the chemical safety document versions, and past activity.

The main prerequisite for the chemical manufacturer or supplier is accurate maintenance of customer records, including contact information and product shipments. These can be fed manually to the distribution system, or Web services can be used to integrate into a manufacturing or ERP system.

Advantages of Automated MSDS Distribution
1. Simplicity, efficiency, and speed. Synchronized updating is simple for you and timely for your customer, taking compliance worries off your plate and theirs.
2. Cost savings. Eliminate printing and postage fees. Most importantly, eliminate the internal costs of manual processing.
3. Consistency, reliability, accuracy. Chemical data compliance is always tied to the product shipments and/or manufacturing/ERP system.
4. Audit trail. Track customer delivery, receipt, and open events to verify regulatory compliance.
5. Customer-friendly access. Thrill your customers with service and communication personalized to their needs.

Closing the Loop
MSDS Distribution is not a complicated business challenge, but it does require careful consideration of the flow of information and business steps required to identify chemical data updates and efficiently communicate those changes to customers, employers, and employees alike. Organizations that are able to close the loop between regulatory and chemical data content changes, MSDS updates, and timely MSDS Distribution stay ahead of the curve for compliance purposes and also business profitability.

References
1. "Facts on Aligning the Hazard Communication Standard to the GHS," OSHA Web site, www.osha.gov.
2. Per the current OSHA Hazard Communication Standard.

This article originally appeared in the October 2010 issue of Occupational Health & Safety.