SDS Authoring Strategies Webinar

Hello, I'm Angela Wheeler. And I'm going to spend a few minutes talking about my background, just why I'm up here talking about SDS Authoring Strategies. Then, what's in it for you? So hopefully, it gets you thinking about ways that you can... You know, you may not even be an SDS author, but if you're producing products, you need to know what good looks like. And we've been coaching some of our clients to do that. 

And I'll try to share a bunch of scenarios that we've been through, or I've been through in my career. I'm going to talk about the SDSs in GHS format. So, they're compliant with WHMIS 2015, also compliant with HazCom 2012. So that's the U.S. version. 

I've got a bunch of things in note. So, you can write down whatever suits your operations. I talked about sampling strategies, some international considerations. So, there's lots of information here. I try to leave you three things. And yeah, you'll have more than three things. I won't harp on anything, but I'm hoping you'll take something away. 

I hope to have half the time for questions. So, feel free to type them in. And when we get to the end, we can just run into that. So, there is a recording and that'll be available afterwards. Maureen's going to handle that. So, I'll get going. [Vocalization] Here we go. 

Over 20 Years of SDS Authoring  

So, I like this photo. I see how the road worms its way. Sometimes it veers off. Sorry, I'm going to... Looking at myself there. I've often felt like I'm taking a detour, but I bet, someday, my path would look quasi-straight like this. 

I was introduced to SDSs in undergrad chemistry back in the '90s. Labels and WHMIS training were the emphasis then. No one actually read the documents, the SDSs. Not so different from now. But then, as a keen occupational hygienist in grad school, we had to write one from scratch. We were told it had to give the worker information on the hazards. 

So later, as a consultant, I wrote SDSs for various clients that needed to ship their products across the country and internationally. And then later, again, consulting, working in the asbestos litigation projects, I had to summarize stacks of court testimonies on exposure profiles. And it gave me proof how little workers were told about the hazards that they were working with. 

Then at Cenovus, I had a product stewardship role. And I maintain the SDS for their products. I worked with the traders and the marketing engineers, developed a sampling strategy for operators. And while I was there, I earned the designation for SDS authoring. It's quite new. It was rolled out in 2013. Just like any other designation, really, you have to show that you understand the body of knowledge, you've been working in the field, and you write a practical test. And then you maintain it every year with development and authoring. 

And so, at that time, in 2014, I was only one of three Canadians who had that designation. And I've been working with SDSs ever since. And you'll see it come through. I think that competency and SDS authoring is essential. And many of our clients have said that too. Merits the comments, "Angela, help them. Our software points out inconsistencies in the SDS writing." But as you know, there's a designation but anyone can write one. 

Why SDS Authoring is Important 

And then, I pass the baton to you. Again, whether you're an author or not, it's important for you, if you're in a position to handle those chemicals or approve chemicals, that you understand what a good SDS looks like. And it does come down to the employer to inform workers of the hazards. So, if they have a poor SDS, that information just gets repeated down the line. 

I totally encourage you to challenge your suppliers. I've had SDSs come across my desk and, you know, there's multiple symbols in there, repeated symbols or the wrong symbols, because I know, I understand the chemistry of it and I push back and many... 

I try not to do the work for them. Like I said, I've done that consulting in the past, but I definitely want the best hazard information for my workers. And I'll ask them to update it. And you'll see some of them will call it MSDS and they're not in the GHS format or over and above. And our software, again, also point that out. So, feel free to advocate for your workplace. 

Testing the product is another thing. If you manufacture a product, definitely get a test done so that you understand the flammability, the corrosivity, the pH, boiling point, vapor pressure, things like that, depending on the characteristics of your manufactured product. Back in the day, the SDSs could just be rubber stamped and/or copied and pasted from other things. But we're in a time now that our testing products is essential to get their proper classification. 

And then note to you as well is document the process. Like any audit will tell you, if it isn't documented, it doesn't count. You really want to be able to show a regulator, your workers, and your suppliers, any of your clients, customers that you have a process for updating your SDS, for creating your SDS, and for management of change. So that's my... 

WHMIS 2015 – GHS Rev. 5 

Into the background. WHMIS 2015 was when we moved from WHMIS 1988 to the new GHS. And when we did that, in Canada, we adopted Revision 5. The U.S. also adopted Revision 5. It's a 16-section format. Historically, I've always written 16-section SDSs because, in my day, it was ISO standard. So, this is an evolution of the rigor we've put into SDSs. 

So, 16 sections, the last 4 are optional. You need the headings in there, but the information just isn't enforced by Health Canada or the regulatory body, even Transport Canada. Section 14 is great way to find the transport information. But Transport Canada doesn't regulate an SDS. I like the fact that SDS people understand where to look, but just to let you know that, yeah, Transport Canada thinks that their shipping document is the proper place for that information. And the SDS is backup. 

Key SDS Sections for Workers 

Key sections for workers. Now I was coaching another colleague and just trying to explain to her, it's a long document. What really matters, as a safety professional, it's good to think of the SDS from the eyes of the worker. As an author, we try to put a lot of information into the SDS. But when we transmit that to the worker, we're trying to pop out certain information. 

So, the product identification. Understanding that one product is different from another by this title. Even if it has the same title, it will have a different manufacturer, so understanding of that different, the product identifiers. 

The hazard identification, that goes into the symbols, the classification, a big one. First aid, accidental release date, self-explanatory. Handling and storage, yeah, how are we going to prep to handle this stuff. Exposure controls, yes, the realm of hygiene and safety.... Oh, sorry. Oh, exposure controls are... I was thinking of my talks. But yeah, exposure controls, again, how they're going to handle that product safely. And then, optionally, disposal and transport, thinking a bit down the road when you have to get rid of the stuff. 

SDS Authoring Best Practices 

So now I have a list. And I've pulled this from other trainings I've done, and it really was a list. So yeah, forgive me all the words. And we'll just take it as she goes. A couple things. 

SDS and Label Authoring Registry 

So, shout out for the SDS and Label Authoring Registry, as I said, and they have a list of SDS authors. So, if you're looking to develop an SDS and you don't want to do it yourself, feel free to reach out to somebody on there. And I'll show at the end, but we do offer SDS through our sister company, Deerfoot. Many of our clients take advantage of that, and it's great, provides some consistency, and there are really some interesting things with QR codes. So, ask about that when you call up.

When Safety Data Sheets and Labels Should Be Updated 

Labels and Safety Data Sheets must be updated when significant information is available for a chemical. And number three, review your SDSs at least every three years. Now this is a legacy item and comes from pre-WHMIS 2015, and it was really something that many countries didn't adopt, and that rigor. But it has been maintained in BC and a couple of the territories. So, it's a great best practice, so reviewing that every three years. Again, put that into your process management change. 

SDS Author’s Bible: The Purple Book 

Purple Book is the author's bible, an SDS Author's bible. And it has flowcharts for classification. We're moving to Revision 7, so we started at 5. We're skipping a few. And both U.S. and Canada are moving to Revision 7 within the... COVID pushed everything out, but they were trying for this year, maybe next year, but keep that on the horizon. And Chemscape will have a diagram to that effect with the changes and such. 

Understand The Substance And Others Like It 

Now this is, again, where you come into play. Even if you're not offering that SDS, understanding what your products are is really good. Sometimes we get the tests taken at the lab and lab is just doing the analysis you've asked for. Really, you're the expert on your products and, you know, you want an SDS author that also understands your substance and not just fill in the blanks or using your computer program to fill in the different sections, the information. 

Review SDS for Similar Products 

And when it comes back, even if you are getting it authored outside, verify that it meets those exposure controls and make sense for your organization, for your industry. That's the value you add in the process. It's so useful to review the SDS for similar products from reputable manufacturers. 

So being a SDS author in the oil and gas, yeah, I'd line them up BP, Exxon, all these. And that's a funny story, just before the Bakken Lac-Mégantic explosion. A couple years before that, I had written an SDS for shale oil [SP] coming out of our Saskatchewan Bakken. I called it Bakken crude. And I had all the data, and I got some backlash from the big guys. I got emails after they found my SDS and I had made it a Packing Group I, highest flammability from a TDG standpoint and a GHS. They aligned. 

And so, yeah, I was getting this hate mail, email, saying, "Crude is never Packing Group I." Like, I'm just going with the data. And I went to my supervisor and I said, "Look, you know, these are coming from reputable oil and natural gas manufacturers." And she's like, "Hey, you got your results. You've gone through your classification scheme. You got the designation. You go with it." 

Well, then Lac-Mégantic happened. And, of course, Cenovus has the only SDS for Bakken crude. And I had all these regulators phoning me and asking me to talk about Bakken crude. And I'm like, "Oh, I shouldn't have made my SDS Bakken crude." And anyway, you know, what happened from that. And now the whole industry knows there's definitely Package Group I out there. And we have new test methods. 

It's very important, again, to review the SDS. You're not just reviewing your SDS, you also reviewing how you sampled and how the regulations changed, like from Revision 5 to Revision 7. There'll be some classification shifts there. And depending on what type of product you have, you want to be on top of that. 

Confirm Consistency Through The Example Between Section 2 And 4 

These things, once you have your classification, they feed through. So that Section 2 is your classification. And it flows. It determines what you're going to say in Section 4 through 7.\ 

Don't repeat H&P statements or pictograms 

Simplify as much as you can. There's a rule of precedence that I'll go into. And definitely, that's more of a cut-and-paste errors. And you don't want that. 

Precedence Rules for signal words 

There's only two signal words, danger, and warning. You don't want them both on your SDS. There's H&P statements, as I said before, they actually do add together. So that's something to simplify. 

And then the pictograms, and I'll go through that. You know, if you have a carcinogen, you're not going to have the exclamation mark, unless there's certain circumstances. If it's aspiration hazard, there's an exclamation mark. But there's a hierarchy of the pictograms as well. 

Oh, this is a good one, Number 10, because I've just gone through one of these.  

Important Not to Contradict Or Cast Out On Information Required On The SDS/Label 

So recently, I had an SDS come through, and it was coded for, "This may be harmful and toxic when inhaled." It can't be harmful and toxic. There's, like I said, a gradation of hazard statements and precautionary statements. So, there are rules, and that's where the Purple Book comes into play. And that's why these registered authors do what they do. 

SDS Is Required for Manufactured Products 

And when you sell them and ship them to clients, they need to be with the shipment or ahead of the shipment. I encourage you to do SDS for by-products and wastes. Now, depending on your jurisdiction, you may have other ways of dealing with waste, but an SDS helps. The SDS for your manufactured products, because we've come into that too, isn't necessarily the same as your waste, so depending on your waste. 

Say, you've got flammable liquid, and now you've got a flammable solid in the end because it's been mixed with your sand treatment facility. Now, this is a solid. So that SDS for your liquid doesn't necessarily apply to your solid. Again, it may require testing. 

And then intermediate products, stuffs in your pipes, you've mixed, you've blended all the ingredients together, and now that's an optional one. It provides hazard information for your contractors and your site crews, if there is a release or taking samples, things like that. So, I've done that as well. 

Here's a funny one. Boiler feed water, it's really condensation. Really, it's processed water that's heated up and blown off the top. But it did contain some salts and such. And it was collecting on the guys' trucks, and they felt that if it was flicked on the trucks, it must be hazardous. And so, it was non-hazardous. But by having an SDS, we could point to the SDS anytime that a question came up and say, "Look, we've done the testing, we've done the classifications, it doesn't come up as hazardous." So, something to think about. 

And then Number 12, this is my last one.  

GHS Does Not Require Testing of Chemicals 

It's a guide to creating those SDSs and the formats. However, manufacturers are permitted to test their products. Manufacturers must use the classification on the information about the chemical that is available, so anything you can collect. You know, if your whole industry, you know that certain things are toxic, then you start putting that into your SDS. 

One of the hardest things I found was getting corrosive. So, the bar for corrosivity in humans is animal testing. And as you can imagine, that's gone out of favor. Nobody wants to do it. I've even posted on internet sites, laboratory sites, where people will take on certain projects for experimental purposes or research purposes, things like that. And, yeah, just nobody wants to do it. 

So, if you can pull that information from the body of knowledge that's already there. We have done a lot of animal testing in history. So that kind of things there. Again, document, document, document, and review when new information comes up because we're always doing better, better research. 

Precedence Rules 

Moving the dial. This is Precedence Rule, and I don't expect you to write it down or memorize it or anything. It's on the net and you can always ask me. But you can see. So, if skull and crossbones appears from your classification, it's toxic. Your exclamation won't. That's gradation. It's a corrosive to skin and metal appears, again, that exclamation will not. Now, if you have the star man for respiratory sensitization, you won't get the exclamation. So, simplifications. 

And then we've got the transport pictogram from TDG or DOT. And you don't need to over placard. They are the same. They mean the same. If your shipment is placarded by for TDG, it meets the requirements for GHS. So, the GHS is once it gets to the worksite. TDG used in transport. But there's also an overlap. Imagine your pallet is sitting on your worksite, waiting to be dismantled. 

Sampling Strategy 

Just a word on sampling strategy. I spoke about TDG. This was one I did on TDG. But the beauty of TDG, if they've put it in the regulation, just what it means to be...what you want to look for a sampling strategy. So, you want a sample, you want a method, a specific apparatus based, and you work with the lab to find out what's best for your product. 

In oil and gas, there's a lot of different analyses and you want to zero in on the ASTM methods that are correct for your product and where it is in their refined state or natural state. So, you want sampling procedures in place. Oh, I can tell you stories about that. 

At one point, we had truckers taking my samples. And you can imagine that they know how to work the controls, but they are not clean. So, thankfully, we had our lab guys go out and take it according to our procedure. And operations guys are great, too. But yeah, I guess, fully trained truckers would rip these. Our truckers, yeah, they were just doing it because I asked. 

Frequency definitely drives consistency and lets you catch when there's upset, but it also lets you determine whether there's a tendency to. And then you can stop sampling or dial back your sampling once you see a trend. And that's just scientific practice, right, and quality control. I'll say that again and again. 

Sampling Strategy Best Practices 

So, I may have repeated myself here. Classification, sampling and classification prior to shipping, these are important for TDG purposes. Sample as close to the place that you are going to capture it for selling. But as you can imagine, if you're doing an SDS for your systems products, you want to do that. Just make a bit of a strategy around where you're taking your samples, so where the interface is with the people and the exposure. 

Sample in appropriate container. Some of them need to be evacuated, some of them need to be acid inside. The lab will send you the right containers. And often, if some of these are remote areas, they'll send a lab technician to take your sample. Procedure for collecting samples. Like I said, there was no procedure for my truck drivers. 

Accredited laboratory, look for that. Some of these are remote sites, you know, we have what we. Sometimes, we had the equipment onsite, partially, like pH and things like that, percent flammables onsite. And so, we could use that. But other things, it gets sent out. Look for an accredited laboratory. That's important for your quality control. And I said about more document.

Quality Control 

Laboratory that has experience, this was around crude analysis. National accreditations include CALA, and SCC. AIHA does accreditations for things like asbestos and hygiene samples. 

Company representative. I've said this before you know your substance. And often you'll know your regulations well, too. Oh, goodness, one of our clients had the SDS written overseas, in Asia, and they didn't have a sense of the TDG. So, they had to rework their SDS such that it met Canadian regulations. So, it's one thing to read a regulation and it's another to be under that regulation, you just have a better understanding of what is necessary. 

So, work with the laboratory, ask them about the analysis, and again, push back and say, "You know, you understand your product, so make sure you get the right tests for your product." 

Standardized procedures. I mentioned ASTM, BS&W, inline calibrated instruments also work because, again, they're calibrated on a regular basis. And, yeah, they're meant for taking samples. 

And then yes, definitely review the results, one of our clients as well. Same thing. I would like to spend a note on that. As a hygienist, we know we can't capture everything. As SDS author, it's one sample or maybe it's three samples. Three samples, three points make a line. 

But if you can bring it together into certain areas at certain times of the year when your process is consistent, things like that, it helps you manage such that you're not taking a sample with every shipment. And, yeah, so, again, as long as you can capture anytime it comes out of your trending and show that you've got enough data to see the consistency of your product, that's where you want to be. 

Compare your test results to previous results and definitely investigate those differences. We have a natural tendency, just you get enough data to like throw one out, "Oh, outlier, outlier." Well, yeah, take the time to figure out why that's an outlier. 

I have that thing on that, too. I, same thing, had my results, and the flammability went off the charts. We had a whole train full of crude heading down to the Gulf of Mexico, and it got down there. And our results showed that it had changed its packing group. 

So, I was on the weekend writing up a new SDS to get it down, because it wouldn't unload the shipment, the whole train. And a train, if you know, only has a certain window to stay at the port. And so, they'll return your train full. And then you got to receive your product back. And that's just not optimal. 

Anyway, because I was able to figure that out, I tracked it back to that investigation. It turns out they bought a different type of diluent to mix with that bitumen, dilbit. And yeah, I was able to alert the process safety people. They didn't realize that they were using a different supplier for their diluent. And they had to do their investigation and make sure that the whole system pressurized, the vessels were okay with that change. 

So, it was kind of a slip up, but somebody found it, and we were able to control any further damage. There was no damage. But having that train sit there was probably considered damage. 

GHS Implementation Across Different Jurisdictions  

I just wanted to let you know that, for one of our clients, we did an investigation of the GHS implementation over different jurisdictions. So, if you write an SDSs or sending, shipping product into China, Europe or UK, I can share this with you, but big one was Canada, U.S. I'll show you the comparisons just so you get a perspective. 

Legislation in US and Canada: OSHA & WHMIS 

Here's the different legislations. So, in Canada, we have WHMIS. And in other countries, they call it different things. We're governed by Health Canada. Down there, it's OSHA. They call theirs the HazCom Standard. And yeah, transport information comes from Transport Canada. Down there, it's DOT. Pesticides are exempt on both sides of the border. They fall under the Pest Control Acts. And so, these pesticides and herbicides, many agricultural products... 

Angela: Okay. Where was I? I'm pretty close to being done. Let me share, I don't know what happened there. 

Male: You started the last slide sort of after the...where you compared Canada, U.S., China, and the EU. 

Angela: Thank you. Okay. 

Male: And then you moved on, one more slide. Right here. That's correct. 

Angela: Oh, that was good. I just started spinning and then I was out, low system resources. That's probably... Oh, sorry about that. What can I do? I'll just keep moving and we'll hope that it stays steady. 

So just Canada, U.S. So SDS for pesticides. Transport Canada, DOT is their equivalent. Herbicides, pesticides, agricultural products, they're coming on board with GHS. They haven't accepted it. So, they understand that there's a... You'll see better and better SDSs, I imagine, as we progress. 

Updating of SDS and Label Information 

Again, more updating, this is important. Suppliers and importers are allowed a period of 90 days when they find out new data. They want to regulate this a bit tighter. Just write this down and aim for that. You don't want to be caught in there. When you've got new data, make sure you're working on updating that SDS. Like I said, work the weekend. Anyway, so and then 180 days for labels. You can see U.S. has a similar thing. They're just worded differently, three months, six months to update. 

SDS Languages 

Labels in Canada and SDSs need to be available in both English and French. And I've come across that too. I didn't feel comfortable writing French SDSs. And so that's when we went, outsourced, and so Deerfoot does help with... And another one of our clients, same thing, looking for Danish SDSs. So yeah, that may be when you reach out for help to a registered author. 

And then, as you can see, in the U.S., they only need the SDS English. But if your workforce is... You can see this; their OSHA site is translated in Spanish. So that's the thing. If your workforce has a predominant language, you need to serve your workforce. And so, you'd be looking for SDSs in Spanish in that particular case. 

But we have clients that...we have our website, we put in a bunch of different languages because, yeah, it wasn't just Spanish. They have, I want to say Tagalog, but different national, different languages. And you'll let us know if there's one that you want to cater to for your workforce. 

Supplier Identifiers 

This is a big one to know and understand that in Canada your SDS needs to include a Canadian address and phone number for the Canadian supplier. In the U.S., same. So, if you're building an SDS for both sides of the border, you'll want to include one for each of those, identification for each of those. 

Classification Cut Offs 

A good thing to know is classification cutoffs. So, when you're building a GHS SDS, the threshold for classification for carcinogens is 0.1%. And then the threshold for other health hazards is 1%. Physical and the environmental have different thresholds. And what I spoke about, the flowchart, will help you with that. 

But, as you can imagine, there are certain things that are harmful under point 0.1%. And consider H₂S as one of them. So many of our clients will put, and Deerfoot clients, will put H₂S in their hazard warning even if it's below 0.1%. And again, that's serving the worker that a consideration outside of... 

Hazards Not Otherwise Classified 

Think of these as your combustibles. Combustible dusts and things like that. So, anything that has falls through the cracks of classification, they have allowances. In Canada, they break them down into physical hazards and health hazards, not otherwise classified. In the U.S., they just have the one bucket and then the corresponding pictogram for that is the exclamation mark. Because they don't really know what's going to fall into that. It just gives room for growth as well. 

Exemptions for Confidential Business Information 

Exemptions. I just wanted to... Again, a lot of words on the slide. And I'm not an expert on HMIRA and the Confidential Business Information, CBI. But our system or software helps with that. And there is a process in Canada, less so in the U.S., you can call anything proprietorial. And you just need to be able to defend it. In Canada, you actually need to HMIRA a number. And once you apply for that number, you can mask the cast number, the chemical identity, or the actual concentrations. 

And I've used this, the prescribed concentrations too. And you can use prescribed concentrations as well if it's a natural product, and you aren't always certain that it's going to be 10%, 20%, 30%. So that helps. Those buckets. 

SDS Final Info Check 

Final info check, just again, reiterate that once you determine your classification, it impacts other sections. So, Section 2 needs to match with Section 3, Section 3 needs to match with 11 and 12, Section 2 also 9, and the H&P statements need to correspond with Sections 7 and 8, storage and handling, and stability. 

Principal References 

I have a list of principal references and let me know if you're interested in having a copy of that. You'll see GHS. The Purple Book is in there. The Chemical Hazard Communication Organization, they were also part of the registry, the AIHA registry. The PubChem is great for getting information for your SDS authoring. ECHA is a European inventory. And the ERG Guide when you're working through the TDG sections, the transportation sections. 

Yeah, you've heard me talk about the registry. This is where it's at. It's what it looks like, developed by AIHA, and the Chemical Hazard Communication. And they have a book of knowledge. And there's Deerfoot consulting is also on that list. 

Woman: I don't see anything in the chat either. 

Angela: Any questions? I did go through a lot and feel free to reach out to me directly to explain anything. 

Branding & Rebranding 

We didn't talk about branding, rebranding. I've been through that too, acquisitions and divestitures. We've acquired a big Conoco bunch of assets and it's being able to review all their SDSs and match them with our current SDSs, and/or if they had ones that were specific to their operations and rebranding them. 

And so, I do recommend reviewing them. But if rebranding is all you can do, just make sure in that disclaimer that that's all you've done, you've rebranded or merged. And then, but again, making sure you've got it on the list to review from top down, health and safety perspective at some point. 

If you've got someone doing your SDSs and you're suspicious of their classifications and such, it's probably your conscience. We've had clients same. I've had the SDS and I've called some of the people I've worked before and said, "Hey, do you realize there's something wrong with your SDS?" And they're like, "I thought so." And they just needed an extra push. 

Like I said, feel free to push back on your suppliers and get the latest and greatest or to have changes. You know, if they've created this, they can stand by their classifications and their wording. Anybody... don't use the word challenge, but yeah, we're all looking for a better product.