Have you eaten your green frog today?
Dr. Robert M. Gresham, Contributing Editor | TLT Lubrication Fundamentals June 2013
You’ll need a realistic plan to comply with the new Globally Harmonized System. Best to get the worst part done first.
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KEY CONCEPTS
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U.S. lubricant suppliers are required to implement the HazCom 2012 standard by June 1, 2015.
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Smaller companies lack the resources and manpower to throw money at the problem by hiring people or consultants.
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Before implementing the new GHS program, educate yourself in what is required in the new regulation.
Recently I have been reading about the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS) for revising our MSDSs (Material Safety Data Sheets) communications. Since so many companies now sell their products to global markets, it seems like a good idea to have uniform product safety and labeling information.
However, there will still be nuances characteristic of various regions or countries. This, of course, will add to the cost, confusion and difficulty in implementation. The U.S. version of the standard, HazCom 2012, was enacted in March 2012 and requires implementation by June 1, 2015—so we at least have a little time.
There are two very good articles written by STLE members that help to explain the differences between MSDSs and the new GHS, including an estimate of the costs to our industry:
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Dr. Neil Canter, Chemical Solutions, “GHS: New Challenges for the Lubricant & Metalworking Fluids Industries,” TLT, March 2013 (click
here).
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Drs. John Howell and Rich Kraska, GHS Resources, “Sticker Shock,”
Lubes ‘N’ Greases, March 2013 (click
here).
Neil, among many other things, delves into some of the nuances of how hazards will be classified or reclassified, which in some cases can result in previously moderately hazardous materials being reclassified to something more hazardous. This can present real problems for a company’s customers and might even result in a loss of sales.
John and Rich try to put a price tag on the effort to comply: ~$100 million for the lubricants industry. That’s a huge number. Some of this is because many lubricant and metalworking companies have numerous sales products. While many of these may be similar, they still will require a discrete SDS and label.
When I think about these difficulties, I particularly feel empathy for small companies. Large companies have whole departments to deal with these kinds of issues; smaller companies often must outsource the problem by hiring companies like GHS Resources. But the smallest companies lack the resources and manpower to throw money at the problem by hiring people or consultants.
About 100 million years ago, I think the 1980s, when the OSHA MSDS regulation came out, I was working for a small company, E/M Lubricants. We had about 1,500 sales products, but fortunately many of them were similar, and a relatively few made up the bulk of our sales.
Still, the problem was to amass an MSDS for each of the raw materials, additives, solvents, etc., we used in our formulations. After a period of study to learn how to write an MSDS, one had to sit down with the batch sheet and a stack of MSDSs for the materials used in the formulation and literally put pen to paper—that’s right, this was before the digital age which now makes the process a lot easier or at least less onerous.
However, you still have to make the correct interpretation of the data, even if you try to use some of the new software programs designed to help with GHS implementation. This is why it’s important for someone in your company to understand the new regulation. Even if you use consultants, you are still accountable.
So how is a small company able to manage this? At least from my experience, it requires sustained self-discipline over years. At my former company, we called this a Green Frog Project. The idea being that if you eat a green frog every morning, the rest of the day won’t seem so bad.
We began by amassing MSDSs on our raw materials from our vendors. My secretary/administrative assistant or whatever we choose to call the position these days created paper files for all these—she was one of the most wonderful people I have ever worked with. Actually now with computers, her job, whatever you call it, has largely gone the way of buggy whips—obsolete.
Regardless, at the end of the day, before she left she would put about 10 or so packets of a batch sheet with the formulation and MSDS for the raw materials in my inbox. Yes, this was when an inbox was an actual box— wood, metal or plastic—into which paper was deposited. I, in turn, came in about 7 a.m. every morning, while the office was quiet and the phones were not ringing, and write MSDSs and labels. That was my green frog for the day.
When my assistant came in, she would have to type these up, make copies, file some and send some to our manufacturing facility so they could make new labels and enclose MSDSs with each shipment. That was her green frog for the day. After we got through it all, we were able to set up a system for any new products we developed and to review older MSDSs and labels for mistakes and upgrades.
So when it comes to implementing the new GHS program, I would recommend first educating yourself in what is required in the new regulation. Second, think it through in terms of your company’s resources. Then develop a realistic plan for implementation. (Incidentally, the two articles cited earlier, as well as their authors, are excellent resources). To put this into perspective, we have approximately 750 working days between now and June 1, 2015. If you have 1,500 formulations, as I did, you would have to average writing two per day right up to the deadline.
So strap on your sense of humor and get started with your daily green frog. Who knows, you might even develop a taste for them.
Bob Gresham is STLE’s director of professional development. You can reach him at rgresham@stle.org.