We can all agree that the GHS does not go as far in terms of harmonization as we might have hoped. Don’t get me wrong, I will take any number of differences in country GHS implementations over the completely different regulatory schemes we had to deal with previously, but it is human nature to try to continuously improve and determine more efficient ways to cope with the issues we face and this is a topic I’ve often found myself thinking about.
Do you watch any of those Do It Yourself (DIY) shows on TV or spend time scrolling through Pinterest to see all the amazingly creative things people are building? I’ll admit that I spend more time doing this than I probably should! I love the idea of DIY because it lets you take something like this, a table that was too big for the job that needed to be done;
Credit: https://www.remodelaholic.com/how-to-make-two-console-tables
And change it into this, which is the perfect fit.
Credit: https://www.remodelaholic.com/how-to-make-two-console-tables
DIY solutions are great because what you build/create can be done to your exact specifications. It will fit the need that you have as opposed to being forced into the size or color contained in your local big box store.
So the question is, can this idea of DIY be applied to GHS? Can we have GHS by Design and create a system that will fit our needs? I think that if we take a more pragmatic view of the regulations and take an inventory of what countries are requiring around the globe, we can do it!
In the pre-GHS world when I was authoring, we would have regional SDSs/MSDSs. They might be for North America or Asia Pacific. In the GHS world, I don’t think region matters as much as the implementation itself does. For example, it is pretty common for countries to not implement building blocks such as Acute Toxicity – Category 5 and Skin Corrosion/Irritation – Category 3. If we look at the country implementations and group countries according to the building blocks chosen, we might see a South American country that closely resembles the implementation of an Asian country and that might be the way to lower the effort it takes to issue SDSs that meet the requirements of the countries in question.
In other cases, a more pragmatic approach to compliance may also need to be taken. For example, three countries have similar implementations, but one of them implemented Acute Toxicity – Category 5. Is it worth the effort to author an additional SDS with the Category 5 classification or would the efficiency that could be gained outweigh the possible risk of competitive disadvantage by showing Category 5 classification on all three country SDSs? These are questions that you will need to ask yourself, but as more and more countries implement GHS and resources continue to be tight, they are reasonable ones to ask.
Finally, whether or not you are able to create your own GHS implementation will be dependent on how you are authoring SDSs. Do you have a process which allows you to be flexible in creating your own rules, or are you using a software system with a very rigid structure? At Sphera, we believe in giving our clients as much flexibility as possible so that they can design a system that works for them. Through the use of our GHS by Design feature, clients can now create their own GHS implementations while taking advantage of all the classification rules that would be used in the country implementations supported in our Product Stewardship tools. Clients can choose the building blocks to implement, the cut-off values to use for classifications such as carcinogens and sensitizers and how the classification calculation itself is performed. Our clients now have the power to take a look at where they are selling products and create GHS implementations that will best meet both their compliance and efficiency needs.
If you could create your own GHS implementations, how would you Design them?
To learn more about implementing GHS by Design, check out our webinar on the topic!.