Featured Article Series: GHS Clarification Issue No. 1As a product manager at Quantum Compliance, I have assisted with promoting the concept of GHS throughout the US and Asia over the past two years through online marketing, email campaigns, sales support, webinars, and seminars. In the span of one week, the Quantum team and I held 3 seminars in 3 different cities, and that experience has left a lasting impression in my mind. I felt like I was a superstar rushing from one venue to another to rehearse and perform concerts. During my communications with clients from a variety of markets, I observed 3 different interesting facts that not everyone knew, and how Quantum has helped address these issues:

1. Most companies’ primary concern is data confidentiality

In order to accurately identify GHS classifications, all GHS conversion services will ask for full product compositions. Understandably, many companies are particularly concerned about handing their confidential product information to other people or exposing the SDSs. This is particularly true for companies who differentiate their products from their competitors by the formulation.

Quantum is committed to our client’s privacy and will always sign a Non-Disclosure Agreement (NDA) before we receive any data from our customers. I always explain to my clients that GHS is not concerned with a full disclosure of your formulations but rather ingredient hazards. Thus, when Quantum authorizes SDSs, we display product compositions in a percentile range, as opposed to an actual exact percentage. Clients can also request to display certain ingredients as “proprietary ingredients” instead of displaying the ingredient name and CAS number. Remember, as long as the hazards are displayed correctly, the compositions do not need to be fully disclosed.

2. Some companies still don’t know suppliers are responsible for providing their products’ GHS SDSs

Some people don’t realize there is a difference between a raw material SDS and a product SDS. For those who are still unsure, a raw material SDS is an SDS for the chemical you purchase. A product SDS, on the other hand, is an SDS for the chemical you produce.

Over the past two years, we occasionally receive calls from companies who wish to convert the product’s raw materials SDSs from MSDS to GHS SDS, but not their company’s product SDS. During these conversations, we inform the client that they have the right to request the GHS compliant SDSs from their suppliers. For all raw materials you purchase from other companies, your suppliers are responsible for converting the MSDSs to GHS compliant SDSs, not you. We always strongly recommend that you receive the latest, most up-to-date GHS SDS for all raw materials from the supplier before you begin work on your own product SDSs.

3. Regulation is not the only factor driving GHS adoption

We all know that regulation enforcement is sometimes not as strict as it should be. GHS-related regulations are no exception. In some markets, the main driving factor motivating companies to adopt GHS is not the regulation but industry standards and certifications.

In Taiwan, many chemical companies in the apparel industry are adopting GHS because industry certification standards require apparel products to be produced in a manner that is not hazardous to humans or the environment. GHS SDS requirements can often meet these certification needs. As such, Quantum has an extensive history of successfully assisting companies with passing certifications by providing detailed and professional SDSs that meet and exceed industry needs.

Conclusion

Environmental health and safety compliance is a constantly growing and evolving industry, and many companies are constantly looking for solutions to stay compliant with regulations and industry standards. I personally think regulations can change from time to time, but following the best practices is always the better way.

What are some interesting facts or lessons you have learned through implementing GHS? Leave a comment below and let us know! If there you are interested in our SDS authoring software or service, contact our sales representative by filling out the inquiry form here.

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