Navigating the Complex World of GHS/CLP and …...Compliance Administration – Ensure local and...

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Navigating the Complex World of GHS/CLP and REACH

Compliance and Impact on the Workplace

Louise Bernstein

March 2015


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• Supply Chain Roles – Which are you?

• GHS/CLP – Downstream Obligations

– Impacts to the workplace

• REACH – Downstream Obligations

– Impacts to the workplace

• GHS/CLP & REACH: General Impacts to the Workplace

Agenda


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• Manufacturer – A company manufacturing a chemical substance

• Importer/Distributor – A company that imports a chemical substance into a country for own use or passes chemical substances onto third parties e.g. a retailer

• Downstream User - Companies that buy chemicals and use in industrial or professional activities

Supply Chain Roles – Which are you?


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• Hazard Classification - Classify hazards to GHS categories

• Hazard Communication - Update SDS and product labels to GHS standards

Manufacturer (Upstream)

• Hazard Communication

• Received GHS SDS available to employees for hazardous products onsite

• Update internally created labels/signs/risk assessments, etc.

• Train employees

Employer (Downstream)

GHS/CLP Obligations


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Purchasing

Alternative, less hazardous purchase

choices for employees and finished goods

Quantity and use limitations for

products deemed more hazardous

Storage, PPE, new waste considerations

GHS/CLP Downstream Impacts


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Product Stewardship

Finished goods may become more/less

hazardous to manufacturer and

transport due to new available data

Market restrictions for raw materials

deemed carcinogenic, mutagenic, or toxic to

reproduction

Reformulation to lessen a finished

good’s hazard category



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Regulatory Reporting

Classification impacts to existing responsibilities

e.g. EU’s Seveso III, CMRs

Monitor regulations to capture ongoing

changes



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Stakeholder Awareness/ Alignment

Educate employees

One size doesn’t fit all – coordinate classification of finished goods

between countries Questions,

document requests from customers

downstream



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Provide use information to suppliers

Take action if use not accounted for/RMM advice

inappropriate

Implement measures specified by supplier to

ensure safe use

Upstream communication of new information on

substance hazards

Evaluate options when using a restricted

substance

REACH Registration for product that is not your

own - Ensure SDS submitted is latest version

Downstream REACH Obligations


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inappropriate


ensure safe use


substance hazards


substance





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inappropriate


ensure safe use


substance hazards


substance





12



inappropriate


ensure safe use


substance hazards


substance





13



inappropriate


ensure safe use


substance hazards


substance





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inappropriate


ensure safe use


substance hazards


substance





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• eSDS

– Size: Printing costs, hard to decimate, use avoidance

– Language: Most Exposure Scenarios are in English

– Availability: Very few eSDS in the market

• Supply Chain protection: Ensuring suppliers are engaging in REACH registrations of your raw materials

• Operational Changes

– Company’s use of a product must match Exposure Scenario

• Sourcing Changes

– Sourcing from alternative suppliers that have accounted for a company’s use of a product

– Raw materials removed from market as they are deemed SVHC, or supplier could not justify REACH registration ROI

REACH Downstream Workplace Impacts


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• Importance of gathering accurate documentation (e.g. SDS) per product

• Increased product information requests up and down supply chain

• Purchasing changes due to changing/more complete product information available – new Personal Protective Equipment (PPE)

• Increased employee training

• Update internal documentation Safety Cards/Risk Assessments/Labels/Placcards

• Need to integrate information between platforms - purchasing/product stewardship/regulatory teams

GHS/CLP & REACH: General Workplace Impacts


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Daunted? Don’t be!

ECHA


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Challenges in Global Workplace Safety Compliance in the World

of GHS/CLP and REACH


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• Benefits of global program management

• Global implementation best practices that achieve compliance assurance

– Selection requirements

– Roll out options

• Best Practice GHS/CLP and REACH activities, with 3E Online Support (demonstration)

Agenda


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Global EH&S = Tightrope Walk!

Differing and Changing Regulations (or lack of)

Resources

Adhering to Corporate Strategy

Budget Allocation

Local Considerations - Logistical and cultural


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What is Global SDS Management?

• Managing one system for all global locations

‐ Application: Information is stored, viewed, and downloaded from centralized access point

‐ Document management: Procedures created to ensure information is kept current


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Why Global Management?

Sharing data and

documents

One “single version of the truth”

• One reference point


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Compliance Administration – Ensure local and corporate due diligence

Centralization – One system for all locations/depts., inventory consolidation and transparency, analysis

Productivity – Removal of duplication of work and reduction of overall SDS management, enabling a focus on other tasks. More is achieved.

Cost Reduction/Avoidance

Increase in overall efficiency removes operational costs. 1:N management – e.g. 1 SDS can be updated for all locations using it

All sites have access to time saving tools SaaS module – no IT time, hardware to purchase, 1 system for all locations

Data repository – Centralized data and SDS used for multiple purposes; regulatory tracking, supply chain analysis, integration with internal tools – Authoring, BOM, ERP, Purchasing, etc.

Why Global Management?


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Research Current Systems

Regulatory Awareness

Select System

Standardize & Localize

Communicate Phase Roll Out

Global Management – Roll Out Steps


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One access point

Support for the wide breadth of regulations

Ability to adapt when regulations change – e.g. GHS/CLP

Ensure multilingual capabilities to support multinational workforce

Scalability – geographically, technologically (infrastructure & IT personnel), increased volume of data stored

Roll Out Steps: Selecting System


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Research Current Systems

Regulatory Awareness

Select System

Standardize & Localize

Communicate Phase Roll Out

Global Management – Roll Out Steps


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1. Geographies

Similar time zones, regulations, languages, logistically easier to

travel around

2. Business Unit/Location Groups

Employees are usually acquainted, similar products, usually share

policies and systems

3. Regulatory Requirements

Focus on countries with immediate regulatory priorities.

GHS & REACH, for example

4. Current Systems

Roll out based on implementation similarities

Global Management – Roll Out Steps: Phased Roll Out


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Best Practices REACH & GHS/CLP Activities and 3E Online Support


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1 – Sourcing Updated Supplier

SDS

2 – Distributing SDS to Employees

3 – Evaluating SDS Changes

4 – Utilizing New Information

5 – Training (Throughout cycle)

Shared GHS/REACH Activities


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3E Online: REACH Support

Most Comprehensive

Downstream REACH support on the market

eSDS Obtainment & Update Alerts

eSDS Flagging

eSDS RMM Timeline

Commencement Report

REACH Annexes Cross-referencing

& Tracking

REACH Registration

Number Reporting &

Tracking

REACH Role/SVT Reports


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Most comprehensive

downstream GHS support on

the market

Obtainment of GHS SDS

Full multilingual GHS data extracted

GHS extraction and comparison reports

Revision Alert to compare changing GHS information

Labels – Sized for use around the

world

GHS classification and labeling

inventory lists, e.g. European, Korean,

and Japan

Data integration into other

platforms (3E & third party)

GHS Employee Training Tools (US)

3E Online: GHS Support


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Thank You

Navigating the Complex World of GHS/CLP and …...Compliance Administration – Ensure local and...

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