On the face of it, compliance with GHS norms sees straightforward. Practical implementation and compliance can be an involved task given how complex it is for the uninitiated.
GHS SDS must be prepared if any chemical or formulation is deemed hazardous according to various classes. The manufacturer, dealer, importer or exporter must prepare GHS Safety Data Sheets when the chemical matches cut off value for various hazard classes. For instance, chemicals falling into the acute toxicity class with a concentration limit of 1% or more must have the appropriate GHS SDS. In the case of chemicals known to be carcinogenic or to affect reproductive organisms, the cut-off value is less than 0.1%. While the format is standardized, it also requires compliance with each section of the 16 sections that refer to identification, composition, first-aid measures, fire-fighting, incidental release, handling, exposure control, stability and other information. If it is just one chemical, it is easy to decide. If a chemical forms part of a formulation the task becomes more complicated and requires expert professional assistance for the right classification.
Preparation of the safety data sheet involves the inclusion of minimum information as regards GHS product identifier, use of the chemical and restrictions along with hazard classification. Manufacturers may hesitate when it comes to disclosing ingredients of a chemical formulation but this is a prerequisite and must be done in a way to ensure confidentiality while disclosing the right amount of information, an area where the expertise of experienced professionals comes in handy.
It is also important that the contents be couched in simple language devoid of any ambiguities. Professionals involved in the preparation of data sheets are fully aware of the pitfalls of language use and know how to avoid them so as to make the contents precisely clear regardless of geographical locations and language usage in various countries. Where English is not the primary language, a document needs to be translated into the local language. An American company, for example, may export to the Far East or to Europe. The SDS must be translated into the local language in addition to English, still another reason for hiring professionals to do the job.
Not all countries have adopted GHS in the same way. It is not mandatory for countries to compulsorily follow the set of recommendations. Some countries, especially those in the European Union, have defined additionalorms. The same American exporter, if he wishes to enter the EU, must also have documents prepared to comply with EU regulations including complying with OSHA GHS implementation in the States. Over 65 countries have adopted GHS recommendations in part or full and they may also have their own regulations. In this perspective hiring experts to compile country, compliant data sheets asserts paramount importance.
In the US alone, GHS comes under the domain of OSHA as well as the EPA, DOT, and CPSC. A company or a dealer may have existing MSDS but these need to be recompiled into a standardized format covering classification, labels, and training. In some cases, chemicals may require reclassification and preparation of SDS from the ground up. Hiring experts to do the job is the safest and sure way to ensure full compliance.