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Implementation of US GHS SDSs and Labels –Sartomer’s Experience

Learn about Sartomer's experience in transitioning their MSDSs to the new GHS SDS format, including the impacts and lessons learned.

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Implementation of US GHS SDSs and Labels –Sartomer’s Experience

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  1. Implementation of US GHS SDSs and Labels –Sartomer’s Experience Lisa Caruso February, 2015

  2. Sartomer – Our Experience • Sartomer transitioned all of their MSDSs to the new GHS SDS format in the middle of a business transition to SAP • What were we thinking? • Didn’t manage the change with customers well • Some customers were happy we transitioned early • Some weren’t because they didn’t want to implement until June 1st • We were the first business unit at Arkema to convert to GHS • We were learning as we were writing…

  3. Impacts • SDS/label hazard classifications changed significantly for many products • Some products had new, more restrictive hazards based on lower (<1%) cut-off’s for CMRs and Skin sensitizers • Had to consider impact of impurities, additives, residual raw materials for the first time • Reformulated some products to avoid labeling • Components previously not listed had to be disclosed • Labeling required for new hazards: • Genotoxicity • Acute and Chronic Ecotoxicity • Many products were re-classified from non-haz to Class 9 for DOT • Increased transportation costs, lack of hazmat drivers

  4. Impacts • Implemented a new labeling system to handle GHS • Learning the new software as we were designing label formats • Sometimes finished labels the day product was scheduled to ship • Purchased new printers for all plants and warehouses to be able to print labels with red borders on pictograms • Products with pre-printed labels were prioritized so we had enough lead time for the new labels • Tried to manage inventory to reduce re-labeling obligations

  5. Lessons learned • GHS WILL NOT result in Harmonization of SDSs/labels across regions and competitors • GHS harmonizes methodology of assessing hazards but does not harmonize outcomes • Classifications will differ between countries: • We see differences between SR US and SR EU for the same products • Not all mixture cutoff levels are the same • Ex. Repro Tox: EU cutoff 0.3%; US cutoff 0.1% • Classification may be different than competitors: • We classify based on the data available to us • They may be classifying based on internal study results only available to them • Need a robust SDS system to handle GHS rules and formats

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