Product safety data sheets don’t get a lot of love in the retail industry, but major changes are underway that will make this formerly mundane document the cornerstone of numerous best practices.
In recent weeks, the Retail Industry Leaders Association (RILA) introduced a new safety data sheet (SDS) template as part of a new environmental data and document information exchange initiative, signaling a significant breakthrough for sustainability, safety and compliance across the retail and consumer goods industry supply chain. The project is an unprecedented advance in environmental data exchange for retailers and manufacturers, the culmination of a major trend in recent years for retailers, manufacturers and service providers to streamline the flow of data and regulatory documents and achieve greater efficiency and accuracy in the management of sustainability, product safety and compliance information in the workplace, transportation systems and the environment. OSHA’s promulgation of its Hazard Communication (HazCom) Standard 2012, which aligns with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling (GHS) framework for global harmonization, was a catalyst for the initiative.
The New Retail Regulatory Reality: Globalization, Harmonization and Systemization
OSHA’s HazCom 2012 Standard has profound implications for retailers in the areas of hazard classifications, labels, safety data sheets and employee training. The new standard has a number of critical and fast approaching deadlines, including December 1, 2013, for employee training; June 1, 2015 for manufacturer and importer product re-classifications and label and SDS updates; December 1, 2015 for distributor product compliance; and June 1, 2016 for workplace labeling and HazCom program updates and additional training.
The Standard and the RILA initiative have together generated an enormous amount of attention, resources and activity on both the upstream creation and downstream management of environmental and sustainability data and documents, as impacted companies move to request, update, provide, revise or manage new information to conform and align with the new initiatives, standards and criteria. The plans and investments to fulfill the new requirements are ambitious and touch suppliers, employees, consumers and communities.
While the new OSHA standard presents the most recent significant change for regulatory data management in the retail industry, it is by no means the only new challenge in recent years. For example, on January 19, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule to harmonize its Hazardous Materials Regulations (HMR) with UN requirements for dangerous goods transportation. The most significant element was the elimination of ORM-D exceptions for consumer commodity shipments by 2014 and the adoption of new Limited Quantity shipment requirements. Shippers started voluntarily using the new limited quantity markings on January 1, 2011, ORM-D AIR markings were no longer accepted as of December 31, 2012 and ORM-D markings will no longer be accepted as of December 31, 2013.
A Strategic Opportunity for Retailer Sustainability Data Management
While retailers must move rapidly toward compliance in fulfillment of the requirements outlined in HCS 2012 and HMR, these changes represent a wonderful and rare opportunity to develop a comprehensive and holistic approach toward the development of a broader sustainability and environmental data management strategy to not only conform with the new demands, but also achieve new heights in optimizing sustainability processes and operations for benefits in productivity and positive impacts on the environment and product and workplace safety. In order to put such strategy formulation in the right context, it is helpful to review recent trends and accumulated requirements for retailers across the enterprise, stores, operations, product lifecycles and supply chains.
The SDS as a Core Foundation
In the retail environment, product environmental, health, safety and sustainability information starts with the Safety Data Sheet (SDS) as a core foundational data source. Safety data sheets have been around for decades as the central required document informing workers of product characteristics and hazards, as well as information regarding proper handling, required protective equipment, emergency and first aid guidance and more. However, new trends and requirements have magnified the role and importance of the SDS as a strategic vehicle for conveying critical product environmental and safety data across supply chains. This heightened role has meant that in many cases the SDS will include additional information in areas such as environmental protection and transportation that go beyond OSHA workplace safety requirements.
A Sense of Urgency around Environmental Data
All of these emerging requirements demand that retailers acquire more knowledge about the products they sell than ever before. It is incumbent upon retailers to manage this data as strategic content for their enterprise operations and not simply view it as a manufacturer responsibility. Retailers now need to closely collaborate with suppliers to obtain a rich set of documents and data about each product, including SDSs, technical data sheets, labels and material disclosures. Retailers must track increasingly complex regulatory requirements related to modal and carrier restrictions from a range of sources including the regulatory authorities, carriers, trade associations and various third party data providers. However, just tracking the requirements and data sources is not enough. Retailers must be in a position to rapidly analyze and assess the impact of regulatory change on the product inventories and urgently take steps to deal with the implications on shipping modes, packaging, labeling, marking, documentation, communications and training.
Retailers face multifaceted challenges when it comes to managing environmental and safety data associated with both existing and new products. For existing products, retailers need to acquire all the required data for their products and develop processes to use the new data in shipping and reporting on their product inventories. For new products, retailers must integrate the data into the product on boarding processes, without disrupting their ongoing business operations, while also assessing impact on their upstream supply chains.
Yet another layer of complexity is the fact that different product categories carry with them different environmental impacts and regulatory data requirements. For example, perfumes and fragrances, nail polishes and coatings, aerosols and batteries all bring unique characteristics, challenges and regulations requiring specialized knowledge and exceptional processes.
The Bottom Line: Data Accountability Demands Data Integrity
Maintaining sustainability, environmental and safety data integrity will be a critical success factor for retailer environmental performance. Such data integrity will depend on deep product knowledge, centralization of previously scattered data, verification of data sources as trustworthy and ongoing change management. Retailers will be held accountable for maintaining data integrity and executing constant updates as changes occur to manufacturer supplied product information, regulations and business needs.
Jeffrey Starr is VP of marketing at 3E Company, a leading provider of environmental health and safety (EH&S) compliance and information management services. For more information, visit http://3ecompany.com/.