Growing complexity confronts companies complying with more regulation and related customer requirements than ever before.
As a June 15 deadline for the U.S.’s OSHA Hazard Communication Standard (HCS) looms, industries and businesses must define a strategy for meeting requirements related to the globally harmonized system of classification and labeling of chemicals (GHS). The United Nations adopted the globally harmonized system in 2003.
Below please find answers to seven good questions about OSHA GHS initiative challenges. Know from the start they involve solutions for “enterprise labeling,” which offers an efficient and flexible way to achieve GHS compliance, while also addressing a wide range of customer and regulatory requirements for doing business in the global supply chain.
#1 How does a company deal with GHS requirements?
HCS and GHS regulation and standards have been in the making for a long time. Now, however, a “hard and fast” deadline looms relative to products containing thousands of different chemicals. From raw materials to finished goods delivery, companies face risk of heavy penalties for non-compliant chemical labeling.
To achieve compliance, a company will need to access multiple data systems and safety-data sheet (SDS) applications. All six HCS elements must be addressed, pictograms filled in, regional requirements and customer needs met, all of which may call for use of multiple languages.
Many companies haven’t even looked at their overall labeling strategy see if it’s even possible to meet the requirements comprehensively. Equally important, is the labeling process able to deal with complexity even beyond that of the 2015 HCS and GHS requirements?
Enterprise labeling addresses complex, global-labeling challenges — including GHS — as opposed to only GHS. Thereby, companies leverage their source of truth for label data; design labels to meet the most complex requirements; enable data-driven labeling to support different label sizes and variations; and empower mission-critical, high-volume printing.
The best solutions stress best practices, with domain-experience embedded in the global deployment of labeling solutions. Enterprise Labeling solution providers also offer specific skills in implementing solutions in different industries and offer 24x7x365 customer support for an organization’s global operations.
#2 Can a single, effective, scalable labeling strategy be implemented?
“Labels,” OSHA says, “are an appropriate group of written, printed or graphic informational elements concerning a hazardous chemical that are affixed to, printed on or attached to the immediate container of a hazardous chemical, or to the outside packaging.”
Any item in the plant containing a hazardous chemical — and every shipment thereof going to any location — must be labeled within the precise guidelines for each destination.
However, GHS compliance is only part of a robust labeling solution. Global supply chain and customer change requests on the one hand, and widely disparate labeling systems across multiple print locations on the other, point to a need for a centralized approach that is yet flexible, scalable, and consistent.
Enterprise labeling goes beyond regulation compliance to ensure global supply-chain consistency, support regional labeling considerations, provide supplier labeling capabilities, simplify adhering to customer-specific labeling requirements and minimize reliance on scarce IT resources.
Instead of disjointed and redundant labeling processes, enterprise labeling offers a scalable labeling solution to cover a multitude of labeling challenges, GHS-centric and beyond.
#3 What are some good ways to access labeling data from regulatory and transactional systems?
With different type data needed for compliant labeling, companies can find that multiple labeling systems — redundant as to data sources — take root over time.
SDS and regulatory information, branding, product identification, pictograms and accommodation for multiple languages are common label features. With diverse labeling solutions scattered through the supply chain, customer hiccups and regulatory failures due to labeling errors potentially can lead to costly fines and business loss.
It’s best to drive labeling directly from the label-data source of truth. Whether regulatory data comes from an SDS database or applications like SAP EHS Management, integrate to key data sources.
Of course, transactional data such as product information, lot and batch numbers, images or customer data can be sourced from content management or ERP systems like SAP or Oracle. This level of integration enables dynamic data-driven labeling, maximizes flexibility and ensures accuracy without replication of data. Regulatory compliance, increased time and cost savings, plus quick response to market needs are the result.
#4 What are some ways to better manage complexity?
Consider the sheer number of possible labeling permutations. To start, there are drums, pails, cans, cases, cartons and pallets. Even tiny little vials must be labeled with GHS info. This leads to different sized labels squatting on variable amounts of printable “real estate.”
For small packages and containers common in chemical industries, GHS-compliant attributes, additional regional regulatory data, customer and branding specifications and language translations must be fitted to the available space.
Capabilities must be such to allow creating any size or shape label required, with out-of-box support for GHS pictograms. Sophisticated field and label logic supports dynamically determining label content based on available white space on the label. Rather than myriads of labels for thousands of chemical product and packaging variations, a rules engine determines label size, format and content based on transactional data.
#5 Can labels accommodate all the languages needed for regulatory compliance internationally?
Chemical industry growth has outpaced the U.S. economy, with shipment values projected to exceed $1 trillion in 2018, up from about $790 billion in 2013. As U.S. exports increase, sophisticated language capabilities can be important to chemical-industry supply-chain participants. Making sure labels comply in any language used is a fundamental consideration.
Full Unicode support ensures that any languages required for labeling, including languages that are read from right to left, can appear together on the same label. Advanced logic capabilities calculate the real estate needed, determining whether sufficient space exists to print a complete warning or text string on a label. This reduces efforts needed to produce accurate, compliant labels.
#6 What about the need for color printing?
Whether using pre-printed stock or printers for pictograms and logos, a labeling solution must accommodate color-printing preferences. Consider the types of printers already installed and the cost of new ones. Assessing the printing capabilities of distribution partners, resellers and customers also comes into it.
Managing countless variations of preprinted stock isn’t always easy. The cost of retooling or coordinating amongst all the supply chain’s printers can seem daunting.
Enterprise labeling offers native print drivers to support color printing.
For GHS labeling, pictograms require at least two colors. For pre-printed stock, sophisticated design capabilities, including business logic, support quality label-printing results to dynamically populate pre-printed pictograms based on transactional data.
For those companies looking to embrace emerging color thermal and inkjet technologies, some labeling solutions provide native print drivers for leading print technologies, including Windows, PCL5c and cab support. Enterprise labeling offers native support for thousands of print devices.
#7 How much flexibility is needed to meet evolving standards and regulations?
Given swiftly emerging chemical regulation by governments around the world, labeling complexity is compounding. For example, the EU REACH & CLP (2006/2008), Taiwan Existing Substance Inventory Available (2012), South Korea “K-REACH” (2015), Australia National Industrial Chemicals Notification and Assessment Scheme (NICNAS) and India’s draft of Hazardous Substances Rules are just some of the many sets of regulations around the world in effect or planned for the near future. Environmental and safety concerns are two of the largest root causes for the urgency of the efforts.
Change is the one thing that can be counted on for the global chemical supply chain. Enterprise labeling enables incorporating changing requirements with ease. Leveraging data driven labeling and a built-in rules engine, support for new regulations and label specifications is achieved without requiring code generation or changes to a myriad of label templates.
The end result is labeling agility and greater responsiveness to evolving labeling requirements without using expensive and scarce technical resources. Business logic for dynamic label selection, and support of regulatory variations through multi-channel supply chains, is the means to responsiveness.
Deborah Grant is industry marketing manager at Loftware, which works with chemical companies around the world to address business challenges ranging from GHS compliance to customer-specific labeling requirements, as well as regional- or language-specific labeling requirements. Before joining Loftware, Deborah served in marketing and sales management positions with international organizations in the communications, industrial printing, and ink manufacturing sectors, with a special focus on Japan-U.S. commerce.
To learn more about GHS and challenges in labeling for OSHA’s revised hazard communication standard,” please access our white paper from industry expert Daniel Levine, or download a recording from our recent webinar How to manage labeling changes for GHS compliance. Also visit our GHS labeling-solutions website at http://www.loftware.com/ghs/.