Currently, chemical manufacturers and distributors are rushing to meet an impending OSHA deadline (June 1, 2015) for reclassifying their chemicals and updating their safety data sheets using criteria outlined in the United Nations Globally Harmonized System (GHS). The end goal is for every safety data sheet in use in the United States to be updated using the GHS format and passed along to downstream users.
The task of authoring a safety data sheet can be arduous. Depending upon the specific chemical and its hazards, the task can include a good deal of combing through disparate and often conflicting test data. Unfortunately, there is no one database comprising all of the necessary hazard information for every chemical and its potential blends. As such, it is often left to the author determine what data to trust, and what data to discard. Moreover, the chemical landscape is always changing, and what was true yesterday, may not be true today. A good example of this paradox is found in the recent dust up over the glyphosate, a herbicide.
The International Agency for Research on Cancer (IARC) — an arm of the World Health Organization tasked with studying the causes of cancer — recently released findings indicating that it now believes glyphosate is a probable human carcinogen.
The fallout from this finding has the potential to drastically alter the hazard classification of products that contain this chemical, and underscores the importance of employing qualified experts to author safety data sheets by illustrating the challenges that arise for authors when new hazard classifications are added to chemicals.
Glyphosate is the most-commonly used herbicide in the world. In use since the 1970’s, it is generally employed to kill weeds and grasses, and works by interfering with the synthesis of amino acids. In 2007 alone, the U.S. agricultural industry used over 180 million pounds of glyphosate.
This determination by the IARC runs contrary of the findings of most major regulatory bodies. The EPA last reviewed glyphosate in 1983, and issued findings determining it to be noncarcinogenic. The European Food Safety Authority conducted a review process in 2013, and also did not recommend a carcinogenic classification. OSHA has no limits for workplace exposure to glyphosate, but does advise against direct skin contact and breathing in airborne glyphosate.
Because of its ubiquity, glyphosate is an excellent example of how an update to a single chemical can have far-reaching impacts.
When new scientific information regarding hazardous chemicals becomes available, and safety data sheets need to be updated, industry best practice is have the information analyzed by authoring experts with a STEM background—preferably including chemistry, biology, physiology and toxicology. Good authors should have the ability to recognize statistical significance, appropriate population sizes and margins of error. Similarly, data should be examined to ensure sound scientific test methods were used and that relevant data has been compiled.
Under the ongoing transition to GHS, many in the EHS space are already experiencing “classification shock” as they realize that under the new guidelines and analyses, their chemicals may be more hazardous than they originally thought. Some are also finding that their original safety data sheets were poorly constructed or relied on outdated tests, or tests for which the critical data points have changed.
Interestingly, the IARC determination was not made in light of new evidence or a new study of the chemical. Instead, the finding was apparently based on a reinterpretation of studies that had already been published. The IARC is scheduled to release a more thorough accounting of the reasons behind their decision later in 2015.
As regulatory bodies around the globe move to align with GHS — and as scientists continue to refine their knowledge of the potential hazards of workplace chemicals — it is safe to assume that we can expect more classification changes in the near future. In order to be prepared, it’s important to have an authoring plan for new or revised SDSs in place. Some companies have the in-house expertise, IT functionality, software, and time to author their own SDSs. However, for those that don’t, contracting with a leading provider like MSDSonline can be an excellent solution.
MSDSonline’s authoring services produce GHS-compliant SDSs written by a team of certified, trained professionals with STEM backgrounds. Our authors create, update, and translate SDSs to meet the compliance requirements of a variety of regulatory bodies. Each SDS undergoes a stringent review process to ensure 100% accuracy and compliance.
To learn more about MSDSonline’s custom authoring options, visit our authoring webpage here.