In-House Safety Data Sheet Authoring & Raw Material Classification
By: Teah Jazey, PRODUCT SAFETY AND REGULATORY AFFAIRS SPECIALIST, email
Many independent companies choose to purchase their own in-house software to author safety data sheets for their products. While this is a great option, it must be used with some caution. Not all safety data sheets are created equal. Dell Tech’s Product Safety Team is authoring new safety data sheets every day; we have the highest standards in the industry. Let’s take a look at what a company must look out for when endeavoring to take on in-house SDS authoring.
Considerations for In-House SDS Authoring Software
Each classification will come with different requirements and you also have to be cautious that all the correct information, as required by applicable regulations, is being included. When considering an in-house software program there are a few compliance requirements that should taken into account.
What are the GHS requirements (Globally Harmonized System) of different or new markets
Is the raw material database originating from reliable data sources?
Do different countries have differing requirements for raw material classifications?
How are the raw material classifications determined?
As you might have gathered, your data sources and raw material classifications are critical when determining the hazard classification for a safety data sheet. A raw material is a building block which will determine the overall hazards for a product.
The overall product classification is impacted by all the raw materials present in a formulation, so when a raw material is classified incorrectly it will trickle down an impact all aspects including the SDS, product label and even transportation requirements. If improperly classified, the effect can be hazardous to the users, the environment, and your bottom line.
Considerations for Raw Material Classification
In order to determine the classification of a raw material, you must consider the following:
Where is your data coming from?
Were proper test methods used to determine the toxicological results from LD50/LC50?
Are your data sources reliable?
Are there specific country requirements for that particular chemical?
Does this raw material have import restrictions?
The source of your raw material data is very important. The information in these sources will determine the overall product classification and any required hazard communication for your product.
In addition to the requirements for GHS, you must also consider other regulations that can have a different impact. This may not be a hazardous impact, but rather an environmental one. If you are bringing a product into Canada, you will want to consider if there are any import restrictions on any of the substances in your formulation. These restrictions are outlined in the Canadian Environmental Protection Act (CEPA). If there is an import restriction it might impact your decision to use that raw material or chemical. Some substances require substance tracking and notification to the appropriate regulatory body, which is in this case, Environment Canada. This might prove to be non-feasible to your company.
All of this must be taken into account when authoring a safety data sheet.
How can Dell Tech help with Raw Material Classification and Safety Data Sheets?
Dell Tech has been in the business of classifying hazardous chemicals for over 40 years. Our team uses a wide variety of sources including but not limited to ECHA, CCOHS, CNESST, IARC, and ACGIH to determine the best classification for an ingredient. In addition to extensive classification experience, our Product Safety Consultants are experts on both Canadian and US GHS regulations. If you are authoring your own safety data sheet documents, you know that the majority of authoring programs do not classify raw materials. This is often the most difficult step in SDS authoring. Determining your overall hazard classification is critical. Here at Dell Tech, we spend endless hours researching every raw material in our database. Let Dell Tech classify your raw materials for you. Simply input the raw material classification we provide into your software program you already purchased. You can be confident that your classification is accurate and compliant using the most up-to-date information available. Areas Dell Tech can help:
- Classify each discrete chemical within your formulation.
- Provide data sources to back up your classification should you be audited.
- Provide guidance on your overall GHS classification and compliance requirements.
- Interpret raw material toxicological results.
In addition to providing guidance on raw material classification, Dell Tech can be your one-stop-shop for SDS solutions. We offer best-in-class SDS authoring services, as well as technical translations for safety data sheets generated outside of Canada and the US. This allows you to skip the cost and uncertainty of in-house SDS authoring if you do not currently own any in-house software. We also specialize in compliance for consumer product labels. Feel free to reach out with any raw material inquiries – we are happy to help keep you in compliance!
English 
