Draft Changes to SDS based on PEG Recommendations is now available @ REACh EU

Dear All,

Based on the initial feedback received from PEG, ECHA made some changes in the text of Safety Data Sheet released during Feb 2010. The major changes are basically relates to initial feedback on the structure and content of the document. Some Corrections to the legal text is also made to reduce the length of the text and to need for translations text. What it means to the business‘s is that they need to consider three different versions of the Annex II during different time periods. Up to 1st December 2010, Between December 2010 and June 2015 and from June 2015 and there could also be some changes needed for the safety data going forward like incorporation of Evaporation rate, Auto Ignition Temperature, Decomposition Temperature

ANNEX II - GUIDE TO THE COMPILATION OF SAFETY DATA SHEETS is valid through 1st June 2007 to 19th June 2010, (present Annex II published with REACH)

ANNEX II - REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A, will be in force from 1st December 2010 to 1st June 2015. (Annex I of commission for substances until the end of 1st June 2015 and for mixtures labeled DPD.

L133/24 “ANNEX II 4 REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A”, will come into force from June 2015 onwards. Annex II of 2010 for substances after 1st June 2015 and for Mixtures Labeled CLP

Full Text of legal Document and associated Excel Sheet showing, which are the recommendations which are implemented in this draft version are available @ ECHA website

SAP EH&S Data Model - Use of Compositions

Dear Friends,

One of the significant aspects to the success of Safety Datasheet Generation / distribution projects is to use and adopt the eixsting data structures. Even for meeting regulatory requirements like to manage REACh Compliance, Volume Tracking or notification management it is necessary to use of right data model. Even, if EHS Data is needed for uploading to ECHA - CLP Notification Tool or REACh - IT, then information from Pure Substances is needed. For meeting these varied requirements there are a number of types of compositions which are available in SAP EHS. So if you are into a client project / needed to manage their data structure for meeting varied requirements, the first thing to notice is to study their existing data model and judiciously use them for meeting the to legislative needs. Remember the point that the priority would be not to disrupt existing business process and achieve the project objective.


The different types of compositions encountered in EHS include, Standard Composition, Exact Composition Based on Products (ECbP), Exact Components based on Components / Starting Material, Hazardous Composition, Legal Composition, REACH Use and Exposure Composition (U&E Comp), Impurities, Hazardous Ingredients (EU), DPDPlus and Pure Composition. Besides above standard types, based on client requirement there might be other flavours too. Here's the short overview of each of the component type.

1) Exact Components based on Products – Substances that are actually contained in the product after the production process has been completed and that can be detected by analysis. Can also consist of products which in turn consists of other components. This component type is generally used by different Expert Rules to calculated secondary data.

2) Standard Composition – Ingredients are substances, that are actually contained in the product after the production proces has been completed and that can be detected by analysis. These are generally taken from ECbP composition type and added together. Thes are calculated by Expert Rules – EHS Standard Comp Rule set.

3) Hazardous Ingredients - On the Composition tab page, specify the contents of the corresponding ingredients with lower limit, upper limit, and average value. In addition, specify the unit for the selected reference value.

4) Components with Occupational Exposure Limits - List of ingredients or ingredient groups (and their quantities) that are subject to an atmospheric limit value and must be specified with this limit value in the EU Safety Data Sheet in the current version), or in accordance with the Technical Regulations for Hazardous Substances.

5) Legal Composition – It’s an optional composition type excluding all impurities from Standard Composition for meeting legal requirements lik REACh. This together with recent release of Impurties –ideally should equal to Standard Composition.

6) REACH Use and Exposure Composition – Contains all substance, which are relevant for supply chain communication. Substances which are used in Compliance Workbench for triggering Supply chain communication.


Thanks

Practical Examples of Exposure Scenarios

Dear Friends,

ECHA has long released the Exposure Scenario Format and also a modified version to incorporate Contributing scenarios based on revised understanding. Exposure Scenarios are the set of information on operational conditions and risk management measures to be communicated to the users. Generally exposure scenario consists of description of conditions suitable to ensure control of risk related to the uses of a substance during the entire life-cycle. Environment, Workers and consumers are included covering one or more exposure uses. Data required for Exposure Scenario include Substance Properties, amounts, emission factors, onsite measures, personal respiration protection, frequency and duration of exposure, frequency and duration of use etc, depending whether it is Environmental Exposure, Workers or Consumer Exposure Scenario.

However one of the challenges in using exposure format is the availability some practical examples of exposure scenarios. Last week ECHA released sample exposure scenarios constituting three substances. These scenarios are specific to Semi Conductor Industry. The lesson's learned therein like how to manage site specific conditions versus Site independent data and how air emission management could generate risk to water compartment are very much helpful to understanding the complexity of the process.The data available therein is very good source to validate SAP EH&S Data models for Exposure Scenarios and also checking suitability of WWI Templates.

Note: Practical Examples of exposure Scenarios can be downloaded from ECHA Site http://echa.europa.eu/news/press_en.asp#press20100906

Thanks

WWI Template - Some Tips

Dear Friends,

Recently I happened to work with WWI tool for eSDS template. I have quite a number of learning’s from this activity, some of them are

- Before working with WWI template ensure you know Microsoft Word 2007.

- Learning all the functionalities of how to align the page breaks, how to maintain page layout, provide indent, margins, spacing etc. This segment is more time consuming than any other exercise. So its always good to begin with good layout and use WWI layout settings with different color schema.

- Always create symbols yourself and don’t use previously created segments if they are spanning multiple paragraphs, at times repeating groups are given for the entire section and if they are not properly taken it creates problems.

- If its data from a single sub node of property tree, better to use SAP WWI Wizard functionality, instead of you creating each of them manually, it gives lot of flexibility interms of how to print etc., make use of this functionality.

- If you are creating tables with multiple components, again print them using Wizard functionality and then use the slave group and master group declarations.

- Advanced functionalities like blank compression / conditional output are very good features so ensuring when to use which functionality is a critical to template creation. Blank compression with alternative, or conditional output with alternative are very good features for printing the symbols in controlled conditions.

- Whenever you come across any template just examine a bit more – you might know more functionality like – how to print Risk Phrases collectively in another section, How to print DG information, how to insert templates based on conditional statements, inserting multiple templates in to a master template, how to print methods, how to use environmental parameters and ID listing data and how to create methods for suiting to your project requirements.

Thanks

Business Process Management - SAP EH&S

Dear Friends,

For a client project at times you need to get involved in identification of as is process or identification of the current management practices of diverse business processes. The intent of such process is either to implenent the process / optimize it or stremline or to merge different systems into a common process. These models / process show a representation of the real world process model built to a certain scale and level of details for a specific purpose. Built to show viewpoint.

Examples of predominant business processes in EH&S include i) Substance and Component management ii) Supply Chain Communication for REACH iii) Generation of MSDS iv) Permit Management v) Incident Accident Management vi) SOP Management etc vii) Dangerous goods and Tremcard processing viii) Label Generation etc.

At times its tempting to use some predeveloped business maps for a new project, however be wise in choosing such material as some scenarios are developed keeping some assumption in mind, which may not hold true for other cases. The objectives of the such model may change during the life of the project, like sometimes a model developed for one purpose might not fit for a broader requirement. There are couple things which one should remember while working on such assignments – i) Why is the process performed ii) Which objects are used/modified iii) Which technology is used iv) Which processes preceed and follow v) Which rules govern the process and which organization unit performs it.

The best approach is to select a key business item (like MSDS generation) and follow it through the process, seeing for which actions are performed and who handles and where it ends up. At time client might be having a business model but following some workaround to achive the current requirement, you need to be careful in mapping such process. Always concentrate on value of each task and check and identify the flow of process correct and check for failure paths if any and see what actions are performed, who handles it and where it ends up. This is provide you a good scenario to actually develop customer scenario. There are many softwares which support this processes like ARIS, Solution Composer, Galaxy, ARIS and other graphical tools like iGrafx.

Thanks

eSDS / MSDS management for meeting Legislative requirements

Dear Friends,

As you might know a safety data is needed for chemical products considered as dangerous to health or environment. According to REACh Article 59, the threshold of concern is typically 1% w/w (solids or liquds) or 02% v/v (gas) or 0.1% of highter for CMR, vPvP, PBT or Cat 1 sensitizers. One of the major changes in the MSDS as extended Safety Data Sheet includes envisaged exposure routes and real use patterns – coversing Exposure Scenarios. One of the obligation also is keeping records of supply of the latest SDS.
So for meeting the Compliance for REACh, Vendor MSDS needed to be managed optimally. Ensuring that new eSDS should be properly analyzed and made accessible to employees inside the organization. Whenever a new chemical is introduced its related MSDS should be properly assessed and informed to all the responsible people. I) MSDS Distribution and II) Processing of external MSDS / eSDS into EH&S are the two requirements for meeting the legislative requirements. So how to achieve these two requirements using existing SAP system ?

The first requirement – making the MSDS accessible to stakeholders – might already be in place for major companies. Like deploying into their internal websites, providing downloadable MSDS into their websites outside SAP or even providing some Document management software to access such information. In this aspect - TechniData’s EHS – WWW tool is a very useful component in meeting MSDS disribution via internet. It automatically converts the RTF documents into PDF and posts them into website, which can be accessed based on different search cabilities – simulating SAP EH&S Report Information System – though not much literature is available in public domain.

The Second Requirement - Making the assessment of the revised MSDS / eSDS requires manual process of actually going through each MSDS identifying the changes (majority it would be Uses, Exposure Scenarios and restrictions) it contains and creating required book marks and releasing it to the internal distribution group. However, the limitation would be it’s a manual process and companies desire some automation here. There are couple of options are there which are still in development stage which will take some more time to realise – like use of “mapping” databases from the local systems and use of some connectors / RFC to actually transfer the contents into SAP system, or using of technology similar to IMDS for processing the worklists to change the content. The other possibility would convert Vendor MSDS to XML files and load them directly into SAP to reflect the changes like some 3rd party data loading tools. SAP software has a in built supply chain communication to derive such information using Emails, Self Service Portals, XML plugins which ensure such processes as part of SAP REACh and Product Compliance 2.0.

Thanks

SAPinsider - Go Beyond Compliance with SAP EHS Management: 1 Best Practice, 2 Challenges, and 4 Opportunities to Reduce Operational Risk

SAPinsider - Go Beyond Compliance with SAP EHS Management: 1 Best Practice, 2 Challenges, and 4 Opportunities to Reduce Operational Risk