Seven Key Questions to Ask Before the 2015 GHS Deadline
As the impending OSHA Hazard Communication Standard (HCS) deadline of June 15, 2015 approaches in the United States, businesses are faced with the urgent need to define their strategy for the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These new regulations and standards have been in the making for some time, but the June deadline is looming for ensuring accurate labeling of products containing thousands of different hazardous chemicals.
If labeling for chemical or hazardous materials is part of your job mix, there are seven key questions you need to ask when moving forward with a GHS initiative.
Question #1: How does my company plan to deal with GHS?
A better question is, can your labeling process deal with the complexity that extends well beyond the 2015 HCS and GHS requirements? Many companies have not spent enough time evaluating their overall labeling strategy to make it the best it can possibly be. For example, from raw materials to finished goods delivery, companies are facing more complexity in chemical labeling with the risk of heavy penalties for non-compliance. Companies need to access multiple data systems and SDS (Safety Data Sheet) applications, include six HCS elements, fill in pictograms, meet regional regulatory requirements, include customer requirements, multiple languages, and more.
Solution #1: Capable software
Look for enterprise-class, broad-based, multi-faceted software solutions designed to handle the rigors of GHS labeling. This allows you to leverage your “source of truth” for label data, design labels to meet complex requirements, enable data-driven labeling that can support different label sizes and variations, and let you perform mission-critical, high volume printing. The best solutions stress the importance of labeling best practices and offer experience in managing the deployment of labeling solutions on a global basis.
Question #2: How can we implement a single scalable labeling strategy?
According to OSHA, “Labels, as defined in The Hazardous Communications System (HCS), are an appropriate group of written, printed, or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.”
Every item on the factory or storeroom floor containing a hazardous chemical, and each shipment going to any location must be labeled within these precise guidelines for each destination in which it will be used. In other words, GHS compliance is only part of a robust labeling solution. In the expanding global supply chain, customers’ change requests, multiple print locations, and frequently disparate labeling systems across organizations all point to a need for a more centralized yet flexible, scalable, and consistent approach to labeling.
Solution #2: Supply chain consistency
Meeting labeling requirements might center on adherence to GHS standards, but there are other important considerations as well. Look for systems that can ensure consistency throughout the global supply chain, enable support for regional labeling considerations, provide supplier labeling capabilities, simplify adherence to customer specific labeling requirements, and minimize reliance on IT resources by facilitating simple and rapid label changes.
Question #3: How can we access labeling data from regulatory and transactional systems?
Getting the right data on all labels is critical. Yet, with many different types of data needed to create compliant labeling, multiple labeling systems with redundant data sources can take root over time. SDS, regulatory information, consistent branding, product identification, multiple languages, pictograms, and more need to be incorporated into labels. But with different labeling solutions scattered throughout the supply chain, the inability to meet regulatory requirements, labeling errors, re-labeling, and failure to address customer needs appropriately can lead to costly fines and even loss of business.
Solution #3: Ability to integrate to key data sources
Comprehensive enterprise labeling solutions are designed to drive your labeling directly from your source of truth for label data. Whether regulatory data is sourced from an SDS database or applications like SAP EHS Management, this approach provides the ability to integrate your key data sources. At the same time, transactional data such as product information, lot and batch number, images or customer specific information can be sourced from content management or ERP systems like SAP or Oracle. This level of integration enables dynamic data-driven labeling, maximizes flexibility, and ensures accuracy without replication of data. The result is regulatory compliance, increased time and cost savings, and shorter time to market.
Question #4: Is there a way to manage requirements for many different products, shapes, and sizes all at once?
One of the major considerations in meeting GHS requirements is the number of possible permutations in labeling. Drums, pails, cans, cases, cartons, pallets, and even tiny vials must all be labeled with GHS compliant information. This means differently sized labels with different amounts of printing “real estate.” In addition to GHS-compliant attributes, proper information needs to be correctly represented on available label space along with additional regional regulatory data, customer and branding specifications, and language translations. In the chemical industry, the smallest packages and containers are especially challenging when it comes to creating the right label.
Solution #4: Field and label logic that can dynamically determine label content.
Look for software with sufficient design capabilities to create any size or shape of label required, along with support for GHS pictograms. Some solutions allow for sophisticated field and label logic to dynamically determine label content based on available white space on the label. For example, rather than creating a myriad of labels for thousands of different chemical products and packaging variations, some software features a “rules engine” that enables label size, format and content to be determined based on transactional data.
Question #5: How can labels accommodate the languages needed for compliance in the United States and overseas?
Making sure labels are compliant in any language is a fundamental consideration in today’s global marketplace. Growth of the chemical industry has recently outpaced that of the U.S. economy with shipment values predicted to exceed $1 trillion in 2018, (up from about $790 billion in 2013). Much of this growth will happen overseas with U.S. exports increasing to keep pace, so sophisticated language capabilities will continue to be important in chemical industry supply chains.
Solution #5: Full Unicode support
Full Unicode support ensures that any languages required for labeling, including those that are read from right to left, can appear together on the same label. Some tools feature advanced logic capabilities that can calculate whether enough space exists to print a complete warning or text string on a label. This capability can greatly reduce the time and effort needed to produce accurate, compliant labels throughout a global supply chain.
Question #6: How can we manage color capabilities?
For GHS compliance, whether by using pre-printed stock or color printers for pictograms and logos, you need a labeling solution that suits your color printing preferences. Consideration of the types of printers already installed, the cost of any new printer acquisitions, and assessing the printing capabilities of distribution partners, resellers, and customers may also be a part of the decision process. Managing variations of preprinted stock isn’t always easy, and the cost of retooling or coordinating between a wide array of printers throughout the supply chain can seem daunting as well.
Solution #6: Use native print drivers to support color printing.
GHS pictograms require at least two colors, although pre-printed stock can in some cases simplify the processes. Still, look for data-driven design capabilities that will support the quality label printing results you need, including the ability to incorporate business rules that can dynamically populate pre-printed pictograms. If you will be taking advantage of color thermal or inkjet technologies, be sure the tools you select provide the necessary native print drivers to ensure accurate printing.
Question #7: How can our strategy include the flexibility required for evolving global standards and regulations?
A very valid concern! Looking at the number of swiftly emerging governmental regulations with regards to chemicals, it is clear that labeling complexity is compounding everywhere. For example, the EU REACH & CLP of (2006/2008), Taiwan Existing Substance Inventory Available (2012), South Korea “K-REACH” (2015), Australia National Industrial Chemicals Notification and Assessment Scheme (NICNAS), and India’s draft of Hazardous Substances Rules—are just some of regulations around the world in effect now or planned for implementation in the near future. Environmental concerns are resulting in regulations placing ongoing pressure to improve safety standards in many countries.
Solution #7: Leverage data driven labeling and business logic
Change is the one thing you can count on in the global chemical supply chain, so be sure the solution you choose enables you to incorporate changing requirements. Solutions that take advantage of data-driven labeling and which have a built-in rules engine, can offer better support for evolving regulations and label specifications without requiring changes to a myriad of label templates. The end result is greater agility and responsiveness to evolving labeling requirements.