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
Showing posts with label REACh. Show all posts
Showing posts with label REACh. Show all posts
Friday, October 29, 2010
Friday, September 10, 2010
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
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
Sunday, August 8, 2010
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
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
Saturday, March 6, 2010
REACh Use and Exposure mapping using SAP EH&S– Industrial Hygiene and Safety
Dear Friends,
Few days back I got a request asking if I write something on Use and Exposure in REACh and How SAP EHS is supported and also about eSDS and GHS. I try to write some high level information. This goes like this –
REACH legislation requires an understanding of how chemical substances are used, specifically, how they are handled throughout their life cycle from manufacture to disposal. For those substances that are hazardous, a risk assessment is required to be performed for each use to demonstrate that it is safe Expsoure scenarios needs to be preparated for hazardous substances tha are produced or imported > 10 t/a. Use and Exposure categories provide specific information tailored to the various user groups about what has to be borne in mind when the substances are used. For REACh Use & Exposure Scenario – Exposure assessment and Risk rating are carried out with Sophisticated 3rd party tools like ECETOC or yet to released CHESAR, for which the current system only the output is stored for reference.
Access the following url to see the Google Presentation on mapping of Use and Exposure in SAP EHS - IH&S Componenet.
http://docs.google.com/fileview?id=0B37ZjPJIaBcONTNiYWVjZDUtZmFiNy00MGNiLTk4ZjUtYWUwMTJhYjBjNWU5&hl=en
Advantages of the model is i) Simplified model taking data from existing systems and proposed REACh – which reduces work effort ii) Mapping multiple substances to one work area – for maintaining Use & Exposure Information further reduces the implementation and reporting effort which can make the system available in shortest possible time period . iii) Existing properties and data is used, as much as possible, such as the existing Use properties from REACh and EH&S.
Some of the classes that can be used without any problem for preparation of eSDS and GHS include– Data maintenance in Exposure Scenario, customer exposure and GHS LABELING. The GHS classification data almost all the data is existing except for some supplementary hazard statement and M-Factors information.
Thanks
Few days back I got a request asking if I write something on Use and Exposure in REACh and How SAP EHS is supported and also about eSDS and GHS. I try to write some high level information. This goes like this –
REACH legislation requires an understanding of how chemical substances are used, specifically, how they are handled throughout their life cycle from manufacture to disposal. For those substances that are hazardous, a risk assessment is required to be performed for each use to demonstrate that it is safe Expsoure scenarios needs to be preparated for hazardous substances tha are produced or imported > 10 t/a. Use and Exposure categories provide specific information tailored to the various user groups about what has to be borne in mind when the substances are used. For REACh Use & Exposure Scenario – Exposure assessment and Risk rating are carried out with Sophisticated 3rd party tools like ECETOC or yet to released CHESAR, for which the current system only the output is stored for reference.
Access the following url to see the Google Presentation on mapping of Use and Exposure in SAP EHS - IH&S Componenet.
http://docs.google.com/fileview?id=0B37ZjPJIaBcONTNiYWVjZDUtZmFiNy00MGNiLTk4ZjUtYWUwMTJhYjBjNWU5&hl=en
Advantages of the model is i) Simplified model taking data from existing systems and proposed REACh – which reduces work effort ii) Mapping multiple substances to one work area – for maintaining Use & Exposure Information further reduces the implementation and reporting effort which can make the system available in shortest possible time period . iii) Existing properties and data is used, as much as possible, such as the existing Use properties from REACh and EH&S.
Some of the classes that can be used without any problem for preparation of eSDS and GHS include– Data maintenance in Exposure Scenario, customer exposure and GHS LABELING. The GHS classification data almost all the data is existing except for some supplementary hazard statement and M-Factors information.
Thanks
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