Understanding Your SDS & Product Data Management Requirements
- It’s All About Access. Employees must have access to accurate SDSs and product data information and it must be available in a timely manner. Both are vital to ensuring information is provided to enforce the appropriate mitigation activity.
- Consider the Geographic Scope of your Compliance Requirements. Regulations are segmented based on the jurisdictions of the governing regulatory agency resulting with compliance obligations potentially being enforced by region, country and industry. Not only is it challenging to determine the right resources for this information, consolidating and organizing this information and combining it with the other pertinent data points is also a challenge.
- Supplier Relations Reign Supreme. Suppliers have an obligation to ensure that they provide SDSs in the format and languages for the countries they distribute to at procurement. There are also obligations in certain countries to notify purchasers of updates to the SDSs for a specified time frame after purchase. Once these obligations expire the responsibility shifts to the reseller. Since these suppliers are not in a direct business relationship with these resellers, resellers have little leverage to demand an SDS.
- Abundant Archiving is Advised. Historical access to SDSs is a specific requirement for some regions or countries and often these regulations span a large time frame. It is a good idea to retain as much of this data regardless of your country obligations as historical data can ensure you have audit trails of SDSs and product data changes. Challenges in this area are associated with resources for storage, maintenance and access to the historical SDS(s).
- Conquer Change Management. Changes to SDSs can result in an entirely new document, or to sections within the SDSs, and these changes can affect the overall accuracy of analysis. Not only is it important to quickly determine what the changes are but how these changes might affect other data points (classification, labeling, safety cards, etc.)
Want to learn more? I am co-presenting a webinar on “Best Practices in SDS and Product Data Management” alongside with Enablon’s Pam Bobbitt on Thursday, March 24 at 8am Pacific / 11am Eastern. We welcome your participation in what’s sure to be a lively discussion. The webinar replay will be available on the 3E website after the live session.