As with all new laws and regulations, whenever GHS is adopted by a country where you ship your products, you need to get ready for the MSDS for GHS or the “SDS” as it is referred to under GHS. Here are a few basic ways to prepare yourself and your company.
As with every new regulatory development, it is worthwhile to perform a quick assessment whether you have the in-house knowledge to understand GHS and the MSDS for GHS. You should determine if you require any assistance from a vendor to acquire theoretical knowledge on GHS.
After you made the assessment, familiarize and train yourself and your employees on the basics of the MSDS for GHS, such as the new pictograms, GHS hazards and their corresponding categories, the Hazard and Precautionary statements, and the new format of the MSDS for GHS, including sections and section titles.
Now that you and your company know more about the MSDS for GHS, it is time to revise and update the classifications of your products. It is important to use the country-specific implementation of GHS, and not the generic purple book GHS, because there may be some minor differences between the two, since a country may choose not to adopt certain less severe hazard categories. Also, carefully study the transition periods in effect, to get an idea of the timeframe to be compliant with GHS.
Once your products are classified for GHS, you can re-create your MSDSs to be in line with GHS, either through software or services. Don’t forget as well to create the GHS labels for your products, using the information included on the MSDS for GHS.
Finally, since the MSDS is used to communicate information on your products to your customers, and since the MSDS for GHS is different than the current MSDS, be prepared to educate some of your customers on the new GHS statements, classifications and pictograms.
As more countries adopt and implement GHS, companies will re-author many of their MSDSs. If you rely on MSDSs for safety and product information, you should be aware of the changes brought by GHS.
There are many differences between a GHS MSDS and a current MSDS that you are used to. The most visible difference is the new set of pictograms. The pictograms on the GHS MSDS are different than the ones on U.S. MSDSs or EU SDSs. The GHS MSDS also has its own Hazard and Precautionary statements, commonly referred to as H&P phrases, although they borrowed heavily from the EU Risk and Safety phrases.
Another interesting characteristic about the GHS MSDS is the standardization of sections and section titles, which will make things easier. Sections and section titles are not the only things being standardized. GHS has standard definitions for hazards, including physical, health and environmental hazards, as well as standard categories for each hazard. It is worth noting that countries implementing GHS 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. The result is that a GHS MSDS of one country can be slightly different than the GHS MSDS of another country.
Finally, the change that is the easiest to remember is regarding the name of the GHS MSDS itself. GHS drops the “M” from “MSDS” and simply refers to the document as the “SDS”. This was already the case in the EU where “SDS” was used. But don’t expect “MSDS” to disappear soon. Since old habits die hard, “MSDS” may still be widely used in the U.S. for some time, but expect within the next 5 years to see “MSDS” phased out in favor of “SDS” from everyday conversation.
All these changes highlight the importance of training your employees, and potentially your customers, on understanding the GHS MSDS, especially the new pictograms and H&P phrases.