Sometimes we get so deep in the forest, that we “can’t see the forest for the trees,” and that is exactly what has happened with the authoring of SDSs. Using current technology, it can take a regulatory expert or chemist in excess of 8 hours to create a single product SDS, once that person is trained to use a particular software. Unfortunately, training them can take days or even weeks. These software programs are complex and often result in wrong classifications.
If there is a regulatory change or new research finding for an ingredient, updating all of the related documents can take weeks or months, only to be repeated again when another change is needed, which will inevitably occur. These inefficiencies are costing the industry billions of dollars unnecessarily.
Why Classification Matters
Of course, there’s the most important health and safety reason – alerting the public to legitimate hazards while not “crying wolf” and alerting them unnecessarily. There are also major business and cost reasons to classify and publish accurately. There are two kinds of mistakes we can make when we classify: over-classification and under-classification. In the language of testing, over-classification is a “Type 1 error” or a “false positive”, saying that something is more of a hazard than it really is; and under-classification is a Type 2 error” or “false negative”, saying that something is less of a hazard than it really is.
These are some of the negative business impacts of incorrect hazard classification.
False Positives: Over-Classification
- Lost Sales – could affect the range of chemicals a company can utilize. If there are internal company standards for a particular chemical classification, they may opt-out of purchasing and using a good, effective material due to its wrongful classification
- Lost Markets – could reduce market share across a wide market (e.g. EU restrictions on certain hazard levels)
- Excessive Compliance Cost – unnecessarily expensive compliance documents and procedures
- Excessive Shipping Costs – unnecessarily expensive hazard protection during shipment
- Excessive Equipment Costs – additional PPE (Personal Protective Equipment) requirements above what’s really necessary
- Excessive Training Costs – additional, unnecessary training costs for higher hazard levels
- Incorrect Occupational Risk Assessments – employers may determine occupational risk assessment as high based on the hazard levels of the misclassified substances/mixtures
False Negatives: Under-Classification
- Health & Safety Risk – could result in improper storage, treatment, exposure, or disposal of a chemical resulting in an unsafe workplace
- Inadequate Remediation – puts consumers, employees, workers, transporters in danger of injuries or fatalities in the event of a chemical release, spill or exposure
- Increased Compliance Costs – could lead to citations, fines and penalties for health and environmental exposure due to having incorrect information communicated on a misclassified chemical or product
- Incorrect Occupational Risk Assessments – employers may carry out an occupational risk assessment as low based on the hazard levels of the misclassified substances/mixtures
Over and under-classifying each impact both safety and the bottom line. Some companies prefer to err on the side of safety, so they erroneously think that over-classification does that. Likewise, other companies focus more on what they believe is the financial cost, so they err on the side of under-classification. In both cases, there are hidden consequences that are not immediately apparent. The costs of “getting it right” and classifying substances and products correctly are less than the costs of “getting it wrong” and either over or under-classifying.
A Better Way to Author Safety Data Sheets
SDSs are hazard documents. They aren’t product specification documents. Yet, it seems everyone approaches them as if they were. They start with the chemical formula and build from the bottom up. The problem with this approach is the number of unique documents that can be created is infinite. How many different ways can 153+ million CAS ingredients be combined? That’s why the right approach is from the top down. That is to say, determine all of the unique combinations of hazards (currently, a little more than 33,000), create master documents that apply to each hazard family/group, determine which hazard family a product belongs in and only modify what is unique to that combination of specific product ingredients (such as whether listed on California’s Proposition 65).
A better way to approach SDS authoring is to categorize and make incremental changes with everything from the regulations to the documents themselves, to use building blocks and cascading principles, storing data elements only once. Doing this makes it possible to make SDSs and any related labels in minutes, not hours or days and to do it without being a chemist or a regulatory expert.
Get in touch with our regulatory experts to learn more about how our authoring software TotalSDS can help save your company time and money.
