Try a Pragmatic Approach to GHS Requirements
In a perfect world, companies would use a uniform Safety Data Sheet and label for a product no matter where in the world it’s sold. That was the idea behind the development of the Global Harmonization System (GHS), which was supposed to streamline hazard communications. Sadly, GHS hasn’t lived up to its promise.
To get countries to agree to the GHS, the United Nations gave them vast leeway to set up customized versions of the system. “The ‘H’ is the joke in the whole GHS scheme, because you have all the different countries wanting to implement it in their own way,” says Carrie Decatur, senior regulatory analyst at Sphera Solutions.
But it might not be as bad as it seems. Decatur thinks product stewards who create unique labels for every country may be working too hard. “You won’t find harmonization if you just look at the regulations,” she says. “When you look carefully at your products and the classifications they fall into, you can sometimes see more harmonization.”
For example, she says, let’s say you’re selling a cleaning product, and you want to use the same SDS in Mexico and the United States. To satisfy Mexico’s requirements, you may have to assign a category 5 hazard level for acute toxicity, which is low. Companies aren’t required to do this under U.S. regulations, but that doesn’t mean they can’t.
In other words, companies often create different Safety Data Sheets for different countries, not because they have to. Sometimes it’s a matter of inertia. Other times, it’s driven by marketing and sales concerns.
“Say you’ve listed the acute toxicity as category 5. Everyone in the profession understands that this represents a lower hazard, but salespeople will say, our competitor don’t have that listed, so our product looks worse,” says Decatur. “You have to decide whether reporting those additional hazards are going to be a problem. Is having a combined sheet better or worse than having to explain the categories?”
Decatur’s pragmatic approach to harmonization is the subject of an upcoming webinar, Finding the Harmonization in GHS. Her presentation, which will look at similarities and differences between different GHS implementations, is designed to help product stewards make generate Safety Data Sheets and labels more efficiently.
“Governments are going to impose what they’re going to impose, but where can we go from here,” she says. “How can we leverage knowledge of our own products and regulatory requirements and start to manage these things?”