MSDS / GHS Walk-through / Auditing

#1
Hi all,

My company has recognized that our SDS records are so out-of-date that our HR department is not even comfortable performing an audit on the records. Any listing of chemicals that we have is recognized as being extremely outdated.

I've been tasked with walking through the plant and identifying all chemicals/materials which we should have SDS records for. I'm not quite sure how to best express the sheer size of this task. We have over 1,000 employees, two paint shops, almost 100 injection molding presses, dozens of assembly lines, a model shop, lab, tooling room... I'm sure I'm missing something.

The good news is that we recognize the deficiency and are working to correct it. I'm looking for any suggestions, or best practices on gathering all chemicals. I considering walking through the entire facility, placing stickers on materials and chemicals as I record them on a list and then distribute notices that containers without stickers on them must be reported immediately — but for anything that is quickly being replenished I see some major drawbacks.

I've contacted third party organizations but since a "walk through" method of identifying chemicals was once performed by a single person, I expect there will be a lot of pressure for me to complete this myself.

Thanks for any help!
 
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John Broomfield

Staff member
Super Moderator
#2
daved,

A mammoth task for which you’ll need all the help you can get from those who know what chemicals/materials they have in their work areas.

I wouldn't call it an audit or a walkthrough. How about “Chem Management” starting with a need to update/create the spreadsheet or database.

In preparing for this I would define the zones (a grid possibly) within your entire premises and then consult with top management to assign the person responsible for each zone or grid.

Then you work with each of these people to collect the data and populate your spreadsheet or database.

To cut the problem down to size you may first want to ask these CM leads to first identify and set aside for disposal the unused and out of date chemicals and materials via your licensed waste disposal/recycling contractor.

Good luck,

John
 

Marc

Hunkered Down for the Duration
Staff member
Admin
#3
<snip> I would define the zones (a grid possibly) within your entire premises <snip>
I usually ask for plant layouts. Most larger companies have them, usually it's a CAD drawing.

Here's an old one (memorable project so it's on my garage wall as a "momento", so to speak).


I am a BIG fan of plant layouts for planning, auditing and various other purposes. I have used them in the past for identifying chemical locations.

In smaller projects I typically made a basic plant layout in a software the company had. Often, though obviously not aimed at making such drawings, I always did pretty well using Microsoft's Powerpoint. Also see Sweeps and Planning

For the heck of it, another "garage wall momento" (since I was out there taking the picture above) from a project I worked on years ago...


My :2cents: because I have found plant layouts to be invaluable for auditing, project planning, and other project related aspects.
 

Ninja

Looking for Reality
Trusted Information Resource
#4
Howdy,
I assume you are in the USA, and my answer is geared to the US OSHA 29CFR1910. version of GHS...
(The Globally Harmonized System is neither)

You are correct that it is a mammoth task. I did this same thing for a site of 55 people (me and a team of 6)...it took over a year to become compliant with current regulations.

You have two primary tasks ahead of you...and ISO or internal audit is a distant third.

#1: What is on site, and how do employees have ready access to the GHS compliant SDS?
- That's huge...but it is the smaller of the two tasks.
If you don't have a GHS compliant SDS, you have to get one.
If you can't get one, you have to document why you cant get it...or make one yourself with a disclaimer of unknowables in section #16.

#2 (the biggie)...it isn't the GHS compliant SDS...it is the container label.
Every...Single...container...must be labeled with product, Signal word, pictograms and all hazard and precautionary statements in the GHS compliant SDS. You got 60 containers of the same thing scattered around...all 60 have to be labeled. If they are all together, you can label the pile once....until you pull one from the pile to use it...then it has to be labeled.​
If you make something, and hand it to someone else...it has to be labeled first.
The only exception is if the container is in the sole control of the person who filled it, and they are present, and the exception only lasts through end of shift. If you go to lunch... it has to be labeled.

  1. We had a "label party", closing production for three days to do nothing but label. (this presupposes that you have quick and easy label printing available).
  2. Then we did a sweep, and confiscated every unlabeled (non-GHS compliant) container...filled an entire loading bay...sectioned off by the area it was confiscated from.
  3. Each person could then go get their stuff back, if they labeled it before taking it.
  4. Then another sweep a month later...filled the loading bay again.
  5. and again
  6. and again
The SDS is a necessary first step...and the labeling then flows from that.
We met directly with OSHA reps looking for shortcuts...and drew the line at "when will you fine us over $100K?"...there are no shortcuts.

Been there, done that...if you'd like to chat, please PM me. Happy to share what I can.

Why is ISO in distant third?

#1 and #2 are law...have been for a couple of years now. If you aren't compliant enough for an HR audit...make sure the OSHA dude/dudette can't find you.
FWIW...having a documented plan for chemical management is also part of 29CFR1910...ISO compliance is simply putting that documented plan/process into your existing doc control mechanism.
 

Ninja

Looking for Reality
Trusted Information Resource
#5
#1: What is on site, and how do employees have ready access to the GHS compliant SDS?
- That's huge...but it is the smaller of the two tasks.
If you don't have a GHS compliant SDS, you have to get one.
If you can't get one, you have to document why you cant get it...or make one yourself with a disclaimer of unknowables in section #16.​


Left out one of the "gotcha"s...

Document all you want about why you can't get the GHS compliant SDS...you still have to have it anyway...since the label elements come from there.

The old MSDS's did not have Signal Word, Pictograms or H&P codes...and you need to have them so you can make a compliant label.

At the end of the day, the material you got in 1970 from a now-defunct company? You have to make the GHS compliant SDS, just to be able to label the container. Document in Section #16 of the SDS you write that it is your best effort based on limited knowledge.

Near the beginning of the process, start putting your feelers out to your local OSHA rep. There are a lot of undefined things in 29CFR1910 that you'll need explained or defined by someone you can point to if you get in trouble. Ask generalized questions, admit nothing, and document the answers...CYA​
 

Randy

Super Moderator
#6
You don't have an ISO or SDS, GHS, or MSDS issue or problem here, what you have is a problem in your compliance to OSHA regulation 29CFR 1910.1200. Meeting your OSHA compliance obligations will resolve everything else.

Follow this link and the links on the page that comes up for help and guidance or get your hands on a for real safety professional to help get you out of the big hole you appear to be in.

Hazard Communication | HAZCOM 1994 Program Guidance | Occupational Safety and Health Administration
 

Ninja

Looking for Reality
Trusted Information Resource
#7
Just to steer you to a more current link...
The 1994 Hazcom got rewritten...

Check out more on the 2012 release: Hazard Communication. - 1910.1200 | Occupational Safety and Health Administration

1994 guidance may not give you all you need for chemicals in the workplace and some other items...

"updated to align with the GHS; a comparison of the Hazard Communication Standard, issued in 1994 (HazCom 1994), with the revised Hazard Communication Final Rule issued in 2012 (HazCom 2012)"

HTH
 
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