by Britt Smith & Dr. Rebecca Pickering
Safety documentation, in increasingly sophisticated forms, has been provided alongside chemical products for many years – some even claim that the practice of providing chemical safety information is evident in the ancient pyramids of Egypt where hieroglyphs were used to convey safety measures to chemical users!
However, since OSHA began requiring Safety Data Sheets (SDS) in the 1980s, the format, content, and surrounding product stewardship processes have evolved swiftly – and many other countries have since implemented comprehensive chemical regulatory programmes regarding the creation and provision of SDSs.
In the knowledge that compliance is not a static act, the wisest regulatory professionals strive to keep abreast of coming changes and trends within the regulatory world – and in this, as the foundation of all hazard communication, Safety Data Sheets are no exception.
At UL, we believe a few key trends will impact and potentially even create fundamental shifts in how Safety Data Sheets are generated and utilised by chemical companies around the world in the coming years.
Evolving Regulatory Landscape
A constantly evolving regulatory landscape is nothing new – but it will continue to shape how the regulatory industry manages Safety Data Sheet generation, particularly as GHS and REACH-model adoptions grow in the coming years. More and more countries are implementing their own standards and regulations, and the pace of change is difficult even for large regulatory teams to match.
This will lead to a demand for more comprehensive solution sets for Safety Data Sheet generation. Technological capabilities have grown to the point where continuous cloud-based content update services will become the new normal – and companies will require regular high-quality deliveries of regulatory data, templates, and automation logic.
Additionally, regulatory teams will need the ability to move with unexpected shifts in the market place and regulatory landscape without solution vendor intervention – waiting for a software update to make urgent changes for compliance will not be an option. Further, because of the complexity involved in global compliance, it will be impossible for a single regulatory team to keep all needed regulatory knowledge in-house, so it will be critical to have a solution supported by broad global regulatory expertise to assist with inevitable knowledge gaps in-house.
Supply Chain Data Management
Another trend that continues to have a substantial impact on Safety Data Sheet generation is the extensive amount of data conveyed up and down the supply chain. As companies develop ever more sophisticated supply chain data management processes, this will have a knock-on effect to Safety Data Sheet generation. Sifting through and interpreting the data will become overwhelming for even large regulatory teams to do with human beings – so they will turn to their solution providers for assistance.
Specifically, they will require solutions to have well-developed integration capabilities to seamlessly share data across systems and deep automation to increase efficiency and accuracy in data processing. This will further develop into a need to automate compliance decisions – for example, by allowing the creation and use of things like industry-specific or retailer-specific black or white lists in process flows and dynamic inventory and volume tracking decision flows.
Companies will also need to find ways to simplify and automate notification processes through their solutions and to derive useful and intelligent reports for their regulatory professionals to use in their broader product stewardship roles. This will become increasingly important for companies doing business in or with the UK as Brexit comes into force.
An added benefit of harnessing automation and integration to manage the ocean of data within the supply chain is that it facilitates and supports the shift towards a hazard communication landscape that is increasingly digitised at all levels, including Safety Data Sheets, ancillary safety documentation such as Worker Instruction Cards, and hazard labels.
Compliance & Corporate Strategy
A paradigm shift in how compliance is viewed with regards to corporate strategy will also greatly influence Safety Data Sheet management in the coming years. Customers at all levels will continue to have an amplified voice alongside higher expectations for corporate stewardship. Savvy marketeers and corporate strategists will realise that, in chemicals, they can use the halo effect created through high quality compliance activity to enhance customer perceptions of product quality and brand strength.
In a world where social media dominates, compliance mistakes will have even greater visibility and consequences than ever before. For these reasons, companies will look for a solution that is more than “just” a Safety Data Sheet authoring package – they will seek comprehensive trustworthy product stewardship platforms to manage traditional hazard communication as well as ancillary safety and compliance documentation, supply chain data collection, and reporting, and to facilitate overarching aims in product stewardship, risk assessment and management, and sustainable product development. It will be critical that the data collected and used for hazard communication purposes can be made available to power other aspects of compliance and to deliver key business insights in all of these areas.
Where previously Safety Data Sheets were treated as an annoying and expensive nuisance to maintain, best in class product stewardship will be seen as a pillar of a chemical company’s corporate stewardship strategy. Solution quality, scalability, and adaptability will be the foremost factors in determining whether a tool is fit for purpose and companies will place increased importance on being able to harness and tailor structured workflows to manage, monitor, and track compliance tasks in an effort to achieve better and more transparent stakeholder communication.
Additionally, the efficiency and data equity gained through a holistic system approach will enable companies to streamline their solution topographies, simplify working processes and data maintenance, and minimise superfluous licensing fees.
With the origins of safety documentation stretching back to the earliest days of the chemical industry, Safety Data Sheets have formed the foundation of professional hazard communication in the chemicals industry for nearly four decades. Over the years, as science and regulations have advanced, so too have these critically-important documents and their role within the chemical community. Companies seeking to rise to the top of their industries must find innovative ways to capitalise on the evolution within the regulatory landscape, high levels of data availability, and consumer awareness to develop a comprehensive compliance strategy that contributes to their overall competitiveness and company objectives. The smartest companies will incorporate nimble and powerful product stewardship platforms to empower their regulatory teams and enable high quality compliance activities.
While Safety Data Sheets have undoubtedly come a long way since the 1980s, it is certain that they will continue to change and advance in the years ahead in ways that we cannot yet predict. For this reason, it is important to adopt an attitude of innovation and continuous improvement within this space – and to recognise that it is only through audacious yet careful reimagining and enhancement of our product stewardship and safety objectives that we will develop the path to tomorrow’s compliance and thereby a safer world.
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