The management of the SDS archive.
Digitize, reorder and optimize document circulation in the company
Cosmetic Technology – 2019
Eduardo Affinito – Every Software Solutions
Safety Data Sheets (SDSs) are the primary source by which hazard and management information on substances and mixtures is conveyed throughout the supply chain. In the face of ever-changing regulations, and consequently a constantly updating body of data, companies often find it difficult to properly find, consult and evaluate SDSs of chemicals in their companies. In some cases, the difficulties encountered may be caused by the failure of raw material suppliers to submit documents (either as first submissions or as systematic submissions of subsequent revisions) and the lack of effective checking of different versions of the same SDS, in many cases scattered among company locations or departments.
Presented below are the results of an analysis of key data regarding SDSs of substances and mixtures conducted in-house in a company with a real presence in the market, in order to demonstrate how digital management of these documents can simplify and optimize the circulation and use of unambiguous, up-to-date and correct information.
Over the years of operation, companies in general, and so do cosmetic companies, receive numerous Safety Data Sheets (SDSs) from their suppliers regarding the chemicals and mixtures that are purchased. In accordance with the legislation governing SDSs (Regulation (EC) No. 1906/2007 (1)), they are provided, either on paper or in electronic form, by the time the substance or mixture covered by the SDS is supplied. Thereafter, SDSs are revised (i) as soon as new information becomes available that may affect risk management measures or new information on hazards; (ii) when an authorization has been granted or denied; (iii) when a restriction has been imposed (1); and, in addition to these cases provided for in the regulation, whenever the supplier deems it appropriate to transmit updated versions, making appropriate changes.
In the risk assessment required under Legislative Decree No. 81 of April 9, 2008 (Consolidated Occupational Health and Safety Act, TUSL), the employer shall preliminarily determine the possible presence of hazardous chemical agents in the workplace and shall also assess the risks to the safety and health of workers arising from the presence of such agents, taking into consideration, in particular (and among other elements): a) their hazardous properties; b) the health and safety information communicated by the supplier through the relevant SDS.
In addition, under the TUSL, employers shall ensure that workers or their representatives have access to any SDS made available by the supplier (2). Similarly, Regulation (EC) No. 1907/2006 requires employers to make SDSs (or information documents where an SDS is not mandatory) of substances and mixtures available to all workers who use them or may be exposed to them in the course of their work (1).
In this framework, where it is easy to glimpse a wide movement of documents in a hopefully increasingly information-rich and up-to-date version, proper and accurate archiving is surely the starting point for any organizational process the company intends to set up.
In addition, with the arrival of new versions it would be necessary to have them immediately available so as to ascertain what elements have been changed and how they affect the assessments prepared in the company. However, previous SDSs should not be deleted, as it may be necessary to prove that one was in possession, at some time, of the previous version. Under the current regulations (1), each actor shall assemble all the information it needs to fulfill its obligations under the regulations and ensure its availability for a period of time of at least 10 years after it last manufactured, imported, supplied or used the substance or mixture, thus also in case of discontinuation of use of a particular product.
The filing of SDSs "on their own"
Initially, a large proportion of companies organize by creating a folder on a disk in the company's computer network, accessible by authorized personnel, where documents (usually in PDF format) are stored as they are transmitted by suppliers.
As time goes on, the number of documents available increases and it can become increasingly difficult to store them in a useful and unambiguously understandable way, as well as to find them. Recognizing files using name alone becomes virtually impossible, as each vendor uses a different nomenclature standard; therefore, attempts are made to make up for this by dividing SDSs into several network folders, but these soon begin to proliferate. In the most frequent cases, a folder is created for each vendor, in order to divide the mass of documents into many small, better manageable pieces.
It is not uncommon to find companies that, for production use of a few hundred products that come with an SDS, have a hundred network folders containing a couple of thousand documents.
In some cases, the company chooses to organize itself by equipping each production department or plant with only the SDSs within its competence (a concept that is in principle correct, not least to avoid the overinformation caused by anyone's indiscriminate access to information not within their competence or interest). In doing so, the matter is further complicated. Indeed, it is usual for PDF documents to be allocated in several folders, so when a new version of an SDS arrives, it should be distributed in several subfolders. Or, again, in cases where different versions relating to different languages of the same SDS are transmitted to the company (imagine the case of a distributor of raw materials who does not carry out rebranding work, who will resell the product in different markets, and who receives from its supplier different versions of the same document, marked with different names or dates), which contribute to the multiplication of archived documents and, likewise, to confusion.
In addition, the various delivery practices adopted by the various suppliers mean that any organizational procedure is further articulated: sometimes SDSs are delivered to the purchasing department, sometimes to the company'sH&S (Prevention and Protection Service Manager), and sometimes they are delivered with the goods and then received directly at the various plants. Many companies have tried to improve their ability to manage this complexity by, for example, compiling Excel sheets containing characteristic product data and, in the most virtuous cases, a link to the document stored in the appropriate folder. But even this method is complex to manage and, in most cases, you lose control of it in a short time.
In the medium term, the result is more or less always the same: the company finds itself managing many more documents than it should or could, and different people are likely to access outdated SDSs that have not been promptly updated in their own reference environment (computer or physical folder).
In doing so, in a short time we end up with duplicate, outdated SDSs or different versions in the various company sites, giving rise to confusion and possible errors. Hence the need to have solutions that actually help, with centralized and unified management of the documents received and digital processing of the data they contain.
Therefore, there is a need to implement a process that allows for the complete management of incoming SDSs in the company, including their receipt, content analysis, verification of the document's compliance with the requirements imposed by the regulations, highlighting of any hazard aspects that may have changed (and that could in some cases compromise the use of a given substance in the cosmetic sector), up to their use in production and the possible archiving of SDSs that are obsolete (because they have been replaced by a new version) or discontinued because they relate to products discontinued from production.
To this end, it was deemed appropriate to conduct an experimental study, using appropriate computer aids, to highlight, by means of a snapshot, what is the common status of document management (and SDSs in particular) in a formulation company, in order to identify appropriate and adoptable strategies in work contexts.
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