Get the Full Picture: Approaches to Hazard Assessment for Product Stewards
How well do you know the toxicity of the chemicals your company handles? Do your coworkers and customers have the same information? Are you sure?
“I’ve seen instances where information has been reported on an SDS and the same company submits a registration, and it does not have the same information,” says Ari Lewis, principal at Gradient.
The problem arises when different people in a company have variable interpretations of the same toxicity data, which leads to different hazard conclusions.
Another huge issue is that some companies don’t have a complete understanding of the potential toxicity of the chemicals in the products they market. “The biggest mystery is that a lot of chemicals are on the market and they have no hazards assigned at all,” says Lewis. “Not assigning a hazard does not necessarily mean there’s no hazard. It may mean that no studies have been conducted, or that an upstream supplier was not diligent in identifying relevant toxicity information. A company can be put in a difficult situation when there is available information out there on a chemical, but it hasn’t been collected and organized in a way that everyone who needs to has access to it.”
The implementation of GHS, along with public interest in product composition means that hazard assessment and communications need be more thorough and consistent. “Whether you’re dealing with three chemicals or thousands of chemicals, you really should have a full picture of their toxicity, and it should be recorded in a way that everybody who needs that information can get it,” says Lewis.
At Product Stewardship 2017, Lewis will share approaches for building a robust hazard management program during the presentation Hazard Assessment: Building Blocks of Compliance and Proactive Product Stewardship. Using real-world examples, she’ll focus on how to evaluate and document approaches to hazard assessment when only conflicting or incomplete chemical information is available.
“My talk goes into why you may see the same chemicals with different hazards assigned to them,” she says. “You should understand why your chemical has the toxicity profile it does and make sure you’re comfortable with it.”