Modifying SDS

Safety Data Sheets (SDS) are widely used for cataloging information on chemicals, chemical compounds, and chemical mixtures. SDS information may include instructions for the safe use and potential hazards associated with a particular material or product. The SDS should be available for reference in the area where the chemicals are being stored or in use. SDS forms make wide use of GHS standards (the Globally Harmonized System of the Classification and Labeling of Chemicals).

In DEACOM, all GHS and SDS information is stored and printed in the software by utilizing Item Master User Fields, System Constants, and User Calculations. User Fields store data for the regulatory items, raw materials, and finished good. System Constants are used for static data and housing all Precautionary Statements designated by OSHA. User Calculations are primarily used for Section 2 of the SDS (explained below) and will calculate the weight percentage of hazardous materials that have classifications which will in turn be used to calculate which classification is reported based on OSHA guidelines. Additional information is available via the SDS Forms page.

Steps towards implementing

Implementing GHS/SDS consists of four steps:

  1. Comparing DEACOM’s generic SDS to the company's current SDS.
  2. Configuring all User Fields, User Calculations, and System Constants.
  3. Importing all data.
  4. Testing the forms output.

Comparing SDS forms

The first step towards implementing GHS/SDS is to compare the DEACOM generic SDS to the company's current SDS. OSHA has requirements and guidelines, however, not everyone will display the information in the same manner. This process will help Deacom understand any special requirements in regard to where the data should be entered, whether it be on the regulatory item, raw material, or finished good.

Configuring User Fields, User Calculations, and System Constants

Once all requirements are identified for the GHS/SDS, all User Fields, User Calculations, and System Constants are configured to house the GHS/SDS related data.

  • User Fields will be created for all data in the 16 sections of the SDS.
  • User Calculations are used to determine the hazardous classification for the Finished Good based on what was selected on the Raw Material or regulatory item.
  • System Constants are generally not changed because the Precautionary statements from OSHA are not updated on a regular basis, however some information such as Emergency contact information from Section 1 would be configured here and would only need to be set up once.

Importing data

One of the most important pieces of the GHS/SDS implementation is importing the data accurately. If currently in implementation, the data specialist will work with the company to map the data from the current system into the DEACOM database. If there is no data in a database to map, an import document is provided where all data can be defined and imported using existing processes.

Testing the output

As is the case with every new change implemented in DEACOM, the new form needs to be tested to ensure it includes all necessary information and looks correct before it is fully implemented in a production environment.

Configuration

  • Also discussed in the Process section below, once all requirements are identified for the GHS/SDS, all User Fields, User Calculations, and System Constants should be configured to house the GHS/SDS related data.
    • User fields will be created for all data in the 16 sections of the SDS.
    • User calculations are used to determine the hazardous classification for the finished good based on what was selected on the raw material or regulatory item. Examples of User Fields are included in the Process section below.
    • System constants are generally not changed because the Precautionary Statements from OSHA are not updated on a regular basis, however some information such as Emergency contact information from Section 1 would be configured here and would only need to be set up once. Note that when creating a new System Constant, Web Services must be restarted before the constant can be used in calculations.
  • The "Print outs menu" security setting muse be set to "Yes" in order to access SDS forms.
  • Item Masters containing active Bills Of Material for this part will need to be setup in order to print the SDS form.

Users should also reference the "Configuration" section of the Managing Part Forms page prior to creating any part form.

Process

Understanding SDS/GHS standards

SDS standards overview

The Occupational Safety and Health Administration (OSHA), in an Advanced Notice of Proposed Rulemaking (ANPR), is proposing a requirement that the information on SDS forms be presented using consistent headings in the sequence specified in the Globally Harmonized System of the Classification and Labeling of Chemicals (GHS). The Agency believes that a standardized order of information would improve the utility of SDS forms by making it easier for users to locate and understand the information they are seeking. A standardized format would also be expected to improve the accuracy of the information presented. The section headings and sequences proposed are:

  • Section 1: Identification
  • Section 2: Hazard(s) identification
  • Section 3: Composition/information on ingredients
  • Section 4: First-aid measures
  • Section 5: Fire-fighting measures
  • Section 6: Accidental release measures
  • Section 7: Handling and storage
  • Section 8: Exposure controls/personal protection
  • Section 9: Physical and chemical properties
  • Section 10: Stability and reactivity
  • Section 11: Toxicological information
  • Section 12: Ecological information
  • Section 13: Disposal considerations
  • Section 14: Transport information
  • Section 15: Regulatory information
  • Section 16: Other information, including date of preparation or last revision

Note: OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction.

GHS standards overview

GHS is an acronym for The Globally Harmonized System of Classification and Labelling of Chemicals. The GHS is a system for standardizing and harmonizing the classification and labelling of chemicals. It is a logical and comprehensive approach to:

  • Defining health, physical and environmental hazards of chemicals;
  • Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
  • Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities. This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United States (U.S.) there are requirements for classification and labelling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration.

The GHS itself is not a regulation or a standard. The GHS Document book establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system. The elements in the GHS supply a mechanism to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate. Regulatory authorities in countries adopting the GHS will thus take the agreed criteria and provisions, and implement them through their own regulatory process and procedures rather than simply incorporating the text of the GHS into their national requirements. The GHS Document thus provides countries with the regulatory building blocks to develop or modify existing national programs that address classification of hazards and transmittal of information about those hazards and associated protective measures. This helps to ensure the safe use of chemicals as they move through the product life cycle from "cradle to grave." There is no specific international implementation schedule for the GHS, however, serveral companies are starting to move to the GHS standard.

GHS hazard classification

The main elements of the hazard classification criteria are summarized below:

Physical hazards

Physical hazards are largely based on those of the United Nations Dangerous Goods System. These regulations and UN test methods can be found at the United Nations website at 1. Some additions and changes were necessary since the scope of the GHS includes all target audiences.

  • Explosives, which are assigned to one of six subcategories depending on the type of hazard they present, as used in the UN Dangerous Goods System.
  • A flammable gas is one that has a flammable range in air at 20 °C and a standard pressure of 101.3 kPa. Substances and mixtures of this hazard class are assigned to one of two hazard categories on the basis of the outcome of the test or calculation method.
  • Flammable aerosols should be considered for classification as Category 1 or Category 2 if they contain any component, which is classified as flammable according to the GHS criteria, that is, flammable liquids, flammable gases or flammable solids.
  • Oxidizing gases are any gas that may, generally by providing oxygen, cause or contribute to the combustion of other material more than air does. Substances and mixtures of this hazard class are assigned to a single hazard category on the basis that, generally by providing oxygen, they cause or contribute to the combustion of other material more than air does.
  • Gases under pressure are gases contained in a receptacle at a pressure not less than 280 Pa at 20 °C or as a refrigerated liquid. This endpoint covers four types of gases or gaseous mixtures to address the effects of sudden release of pressure or freezing which may lead to serious damage to people, property, or the environment independent of other hazards the gases may pose.
  • A flammable liquid is a liquid with a flash point of not more than 93 °C. Substances and mixtures of this hazard class are assigned to one of four hazard categories on the basis of the flash point and boiling point.
  • A flammable solid is one that is readily combustible or may cause or contribute to fire through friction. Readily combustible solids are powdered, granular, or pasty substances which are dangerous if they can be easily ignited by brief contact with an ignition source, such as a burning match, and if the flame spreads rapidly.
  • Self-reactive substances are thermally unstable liquids or solids liable to undergo a strongly exothermic thermal decomposition even without participation of oxygen (air). This definition excludes materials classified under the GHS as explosive, organic peroxides or as oxidizing.
  • A pyrophoric liquid is a liquid that, even in small quantities, is liable to ignite within five minutes after coming into contact with air. Substances and mixtures of this hazard class are assigned to a single hazard category on the basis of the outcome of the UN Test N.3.
  • A pyrophoric solid is a solid that, even in small quantities, is liable to ignite within five minutes after coming into contact with air. Substances and mixtures of this hazard class are assigned to a single hazard category on the basis of the outcome of the UN Test N.2.
  • Self-heating substances are solids or liquids, other than a pyrophoric substance, which, by reaction with air and without energy supply, is liable to self-heat. Substances and mixtures of this hazard class are assigned to one of two hazard categories on the basis of the outcome of the UN Test N.4.
  • Substances which on contact with water emit flammable gases are substances that, in contact with water, emit flammable gases; or, are solids or liquids which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities. Substances and mixtures of this hazard class are assigned to one of three hazard categories on the basis of the outcome of UN Test N.5, which measures gas evolution and speed of evolution.
  • Oxidizing liquids are liquids that, while in itself is not necessarily combustible, may, generally by yielding oxygen, cause or contribute to the combustion of other material. Substances and mixtures of this hazard class are assigned to one of three hazard categories on the basis of the outcome of UN Test O.2.
  • Oxidizing solids are solids that, while itself is not necessarily combustible, may, generally by yielding oxygen, cause or contribute to the combustion of other material. Substances and mixtures of this hazard class are assigned to one of three hazard categories on the basis of the outcome of UN Test O.1.
  • Organic peroxides are organic liquids or solids that contain the bivalent -0-0- structure and may be considered a derivative of hydrogen peroxide, where one or both of the hydrogen atoms have been replaced by organic radicals. The term also includes organic peroxide formulations (mixtures). Substances and mixtures of this hazard class are assigned to one of seven 'Types', A to G, on the basis of the outcome of the UN Test Series A to H.
  • Substances corrosive to metal are substances or a mixtures that by chemical action will materially damage, or even destroy metals. These substances or mixtures are classified in a single hazard category on the basis of tests (Steel: ISO 9328 (II): 1991 - Steel type P235; Aluminum: ASTM G31-72 (1990) - non-clad types 7075-T6 or AZ5GU-T66). The GHS criteria are a corrosion rate on steel or aluminum surfaces exceeding 6.25 mm per year at a test temperature of 55 °C.
Health hazards
  • Acute toxicity includes five GHS categories from which the appropriate elements relevant to transport, consumer, worker and environment protection can be selected. Substances are assigned to one of the five toxicity categories on the basis of LD50 (oral, dermal) or LC50 (inhalation).
  • Skin corrosion means the production of irreversible damage to the skin following the application of a test substance for up to 4 hours. Substances and mixtures in this hazard class are assigned to a single harmonized corrosion category.
  • Skin irritation means the production of reversible damage to the skin following the application of a test substance for up to 4 hours. Substances and mixtures in this hazard class are assigned to a single irritant category. For those authorities, such as pesticide regulators, wanting more than one designation for skin irritation, an additional mild irritant category is provided.
  • Serious eye damage means the production of tissue damage in the eye, or serious physical decay of vision, following application of a test substance to the front surface of the eye, which is not fully reversible within 21 days of application. Substances and mixtures in this hazard class are assigned to a single harmonized category.
  • Eye irritation means changes in the eye following the application of a test substance to the front surface of the eye, which are fully reversible within 21 days of application. Substances and mixtures in this hazard class are assigned to a single harmonized hazard category. For authorities, such as pesticide regulators, wanting more than one designation for eye irritation, one of two subcategories can be selected, depending on whether the effects are reversible in 21 or 7 days.
  • Respiratory sensitizer means a substance that induces hypersensitivity of the airways following inhalation of the substance. Substances and mixtures in this hazard class are assigned to one hazard category.
  • Skin sensitizer means a substance that will induce an allergic response following skin contact. The definition for "skin sensitizer" is equivalent to "contact sensitizer". Substances and mixtures in this hazard class are assigned to one hazard category.
  • Germ cell mutagenicity means an agent giving rise to an increased occurrence of mutations in populations of cells and/or organisms. Substances and mixtures in this hazard class are assigned to one of two hazard categories. Category 1 has two subcategories.
  • Carcinogenicity means a chemical substance or a mixture of chemical substances that induce cancer or increase its incidence. Substances and mixtures in this hazard class are assigned to one of two hazard categories. Category 1 has two subcategories.
  • Reproductive toxicity includes adverse effects on sexual function and fertility in adult males and females, as well as developmental toxicity in offspring. Substances and mixtures with reproductive and/or developmental effects are assigned to one of two hazard categories, 'known or presumed' and 'suspected'. Category 1 has two subcategories for reproductive and developmental effects. Materials, which cause concern for the health of breastfed children, have a separate category, Effects on or Via Lactation.
  • Specific target organ toxicity (STOT) 2 category distinguishes between single and repeated exposure for Target Organ Effects. All significant health effects, not otherwise specifically included in the GHS, that can impair function, both reversible and irreversible, immediate and/or delayed are included in the non-lethal target organ/systemic toxicity class (TOST). Narcotic effects and respiratory tract irritation are considered to be target organ systemic effects following a single exposure. Substances and mixtures of the single exposure target organ toxicity hazard class are assigned to one of three hazard categories. Substances and mixtures of the repeated exposure target organ toxicity hazard class are assigned to one of two hazard categories.
  • Aspiration hazard includes severe acute effects such as chemical pneumonia, varying degrees of pulmonary injury or death following aspiration. Aspiration is the entry of a liquid or solid directly through the oral or nasal cavity, or indirectly from vomiting, into the trachea and lower respiratory system. Substances and mixtures of this hazard class are assigned to one of two hazard categories this hazard class on the basis of viscosity.
Environmental hazards
  • Acute aquatic toxicity means the intrinsic property of a material to cause injury to an aquatic organism in a short-term exposure. Substances and mixtures of this hazard class are assigned to one of three toxicity categories on the basis of acute toxicity data: LC50 (fish) or EC50 (crustacean) or ErC50 (for algae or other aquatic plants). In some regulatory systems these acute toxicity categories may be subdivided or extended for certain sectors.
  • Chronic aquatic toxicity means the potential or actual properties of a material to cause adverse effects to aquatic organisms during exposures that are determined in relation to the lifecycle of the organism. Substances and mixtures in this hazard class are assigned to one of four toxicity categories on the basis of acute data and environmental fate data: LC50 (fish) or EC50 (crustacea) or ErC50 (for algae or other aquatic plants) and degradation or bioaccumulation.

Classification of mixtures

The GHS approach to the classification of mixtures for health and environmental hazards is also complex. It uses a tiered approach and is dependent upon the amount of information available for the mixture itself and for its components. Principles that have been developed for the classification of mixtures, drawing on existing systems such as the European Union (EU) system for classification of preparations laid down in Directive 1999/45/EC. The process for the classification of mixtures is based on the following steps:

  1. Where toxicological or ecotoxicological test data are available for the mixture itself, the classification of the mixture will be based on that data;
  2. Where test data are not available for the mixture itself, then the appropriate bridging principles should be applied, which uses test data for components and/or similar mixtures;
  3. If (1) test data are not available for the mixture itself, and (2) the bridging principles cannot be applied, then use the calculation or cutoff values described in the specific endpoint to classify the mixture.

Setting up and structuring Formulas

The Formula structure in DEACOM is used to calculate the Section 2 Classifications for Hazards Identification. If Raw Materials are pure, hazardous chemicals, additional formula setup is not needed to capture this information. If hazardous components of Raw Materials do need to be classified, a regulatory Bill of Materials (BOM) will need to be configured.

To enter a regulatory BOM, create a new Formula for the Raw Material and add all hazardous CAS items. When adding the parts, the quantity must be the percentage of the material in the form of a fraction. For instance, if there is 60% ethylene glycol in the product, 0.60 would be used as the quantity. Refer to the Managing Formula Revisions page for further information. Once all items have been added to the BOM, check the "Active" and "Regulatory" flags to indicate it as an active, regulatory BOM.

Note: Regulatory BOMs are not used for costing purposes, the sum of the cost of the components do not roll up to the parent part. Regulatory BOMs are also fixed to produce one unit of weight or volume of the purchased part, and the non-reportable subcomponents do not have to be listed - it is set to be calculated with a batch yield of one because regulatory BOMs do not have to be complete. It is also recommended that the CAS or hazardous items be set to non-purchasable, non-salable, and not manufactured on their Item Master Properties tab since these items can never be stocked and do not need to be available to those modules of the software.

Configuring User Fields, User Calculations, and System Constants

User Fields

User Fields are set up during the GHS/SDS implementation and are normally not changed, like the System Constants. At minimum, there can easily be 100+ fields set up to store all of the data for the regulatory items, Raw Materials, and Finished Goods. DEACOM will import a set of User Fields to start configuring based on the stock SDS and will be a starting point for configuring User Fields to meet the company's needs. Refer to Configuring User Fields and User Calculations for process information.

Section 2: Hazards Identification are configured to be pick list items and have text set up in a very specific way for each of the classifications and categories. Assume there is a User Field for "Acute Toxicity: Oral" with a Field Type of "Pick List". While defining the pick list options, one option, category 1, can be listed as “Category 1/H300” and the text associated with that pick list is “1|D|H300|Fatal if swallowed.”

Breaking it down, 1 stands for the category, D represents the signal word Danger, H300 is the hazard code, and Fatal if swallowed is the Hazard codes text associated with H300 in this example. All categories are set up with the same scheme so calculations and expressions can pull the correct information between the pipe delimiters “ | “.

User Calculations

One of the more challenging pieces of the GHS/SDS is the User Calculations. Most companies will only have calculations for Section 2: Hazards Identification but they can be set up for bringing information from regulatory items, Raw Materials, and Subassemblies to the Finished Good. DEACOM will import the User Calculations for Section 2 because these have been configured based on the OSHA purple book.

There are two sets of BOM User Calculations for determining the classification based on the regulatory or Raw Material components. The first set determines the weight percentage of a classification across all regulatory/Raw Materials. The second set determines which classification should be displayed on the GHS/SDS based on OSHA rules. For example, Acute Toxicity Category 1 would only be classified if there is more than 1% of that category in the mixture.

There is one User Calculation for every category to calculate the weight percentage of a classification. For example, there are 5 categories for Acute Toxicity Oral and therefore there are 5 User Calculations to determine how much weight of each possible classification there can be. For every classification, there is a sum calculation to capture fractions and report the lowest classification for precautionary measures. These are not required and can be deactivated as needed.

Weight Percentage Calculations - Using Acute Toxicity Oral Category 1 as an example, the User Calculation expression would appear as “IIF(u_acute_toxicity_oral = '1|D|H300|Fatal if swallowed.', (totwgt/uc_totwt)*100, 0)”. What this is saying is if any regulatory/Raw item has '1|D|H300|Fatal if swallowed.' selected (remember that this is the behind the scenes text from the User Field configuration), divide the total weight of the material by the total weight of the Formula, this will give the percent in fraction form. Multiply the fraction by 100 to give the actual percentage of the material. If any of the regulatory/Raw items do not have category 1 selected, it will do nothing which is what “, 0” is representing at the end of the expression.

Hazardous Classification Calculations - Using Acute Toxicity Oral again as an example, this calculation calls on the weight percentage calculation to determine which category needs to be displayed on the SDS based on the OSHA purple book. The calculation covers all categories in one expression starting with the first category and ending in the least hazardous category.

  • IIF(uc_acute_toxicity_oral_sum1 >= 1, '1|D|H300|Fatal if swallowed.',
  • IIF(uc_acute_toxicity_oral_sum2 >= 1, '2|D|H300|Fatal if swallowed. ',
  • IIF(uc_acute_toxicity_oral_sum3 >= 1, '3|D|H301|Toxic if swallowed. ',
  • IIF(uc_acute_toxicity_oral_sum4 >= 1, '4|W|H302|Harmful if swallowed. ',
  • IIF(uc_acute_toxicity_oral_sum5 >= 1, '5|W|H303|May be harmful if swallowed. ',
  • IIF(uc_acute_toxicity_oral_sum >= 1, '5|W|H303|May be harmful if swallowed. ', '')))))) To explain the expression in further detail, the first IIF statement is saying, is there at least 1% of category 1 in the formula. If there is, the result would be '1|D|H300|Fatal if swallowed.', which again is displayed in this manner because the Part Form will use different parts of this text to generate Section 2. If there is not more than 1% of category 1, move onto the section IIF statement, is there at least 1% of category 2 in the formula. If there is, the result would be '2|D|H300|Fatal if swallowed.'

System Constants

System Constants are almost never changed after implementation unless static data needs to be updated or OSHA assigns new Precautionary codes/statements. In the event that System Constants do need to be updated or added, this can be done by navigating to Tools > Maintenance > System Constants. From here, select the constant that needs to be updated or click the "New" button to add a new one. Note that these can be used for other areas of the system and are not only for GHS/SDS.

All precautionary statements are set up with the name being the code and the statement listed in the "Notes" field. They are set up in this manner because the text is what will print on the Part Form and the name is used in the expression to determine which code is associated with each hazard classification.

Designing the Part Form

GHS and SDS labels are very similar in regards to displaying Section 2 information and some firefighting measures. When implementing GHS/SDS, DEACOM always starts with the SDS since the GHS contains the same information and can be copied to it based on what was configured during the SDS setup.

Designing the SDS form

There are three main designs to the SDS, two of which are re-used throughout the report. Again, the most difficult being Section 2, printing regulatory/Raw Materials and data entered on that level (examples would be Section 3 and LC/LC50), and printing data entered on the Finished Good.

Section 2: Hazards Identification

Section 2 uses the output of the hazardous classification calculation that was covered earlier. If the Finished Good has an Acute Toxicity Oral: Category 1, then the text that is parsed in Section 2 would be '1|D|H300|Fatal if swallowed.'

The first piece of information that is required in Section 2 is displaying the classification. This is determined by the first letter of the text from the calculation which would be ‘1’ using '1|D|H300|Fatal if swallowed.' as an example. The classifications expression covers all classifications using the same expression several times with different User Calculations in the IIF statement. The following expression is used to determine if there is Acute Toxicity Oral associated with the Finished Good:

  • IIF(EMPTY(uc_acute_toxicity_oral),"","Acute Toxicity - Oral: Category " + Left(uc_acute_toxicity_oral, AT("|",uc_acute_toxicity_oral)-1) + CHR(13)) +

This is first looking to make sure that there is a value and it is not blank though the “EMPTY(uc_acute_toxicity_oral)” portion. If it is empty, it will do nothing and move onto the next classification. If there is a value, anywhere from Category 1 - 5 in this case, it will print the text “Acute Toxicity – Oral Category” on the form and then print the first letter of the text '1|D|H300|Fatal if swallowed.' which would be 1. On the Part Form, it would display as “Acute Toxicity – Oral Category 1”.

Pictograms and signal words

Pictograms and Signal word use the second character in the classification text and will always be a D or W for Danger or Warning because signal word is required by OSHA and pictograms are based on the same signal word. The expression below is very similar to the classifications expression. It has an expression for every category and looks to see if the second character is a D or W.

  • IIF(SUBSTR(uc_acute_toxicity_oral, AT("|",uc_acute_toxicity_oral)+1, 1) = "D" OR

The expression will start by looking for the character after the “|” in the text that is generated by the User Calculations that were covered earlier. Using the example '1|D|H300|Fatal if swallowed.', the second character is D and therefore it would print Danger on the SDS. If there are no Danger signals, it would then determine if there is a W after the first “|” and if there is, Warning would print. All associated pictograms would print based off what the signal word is for the classifications.

Hazard statements

Hazard Statements are embedded in the text and Part Form expressions will print the statement as long as there is one present. The expression below will print the h-code and hazard statement for each classification.

  • IIF(EMPTY(uc_acute_toxicity_oral), "", SUBSTR(uc_acute_toxicity_oral, AT("|",uc_acute_toxicity_oral,2)+1,4) + " | " + SUBSTR(uc_acute_toxicity_oral, AT("|",uc_acute_toxicity_oral,3)+1) + CHR(13)) +

The first portion of the statement will determine if the classification exists. If it does not then it will print nothing, otherwise it will print the h-code, a pipe delimiter (this is printed for cleaner design on the print out), and then the hazard statement. Using the Acute Toxicity Category 1 example, '1|D|H300|Fatal if swallowed.', the H300 would be the hazard code, and Fatal if swallowed. would be the hazard statement on the print out.

Precautionary statements

Precautionary Statements is the final piece of Section 2 that prints the applicable precautionary code and statement based on the User Calculation that determines the classification. All precautionary codes are designated by OSHA and are associated with a Hazard Code. By having this information available, an expression (below) can be written that prints the appropriate precautionary code if and of the Hazard Codes are calculated on the Finished Good.

  • IIF( SUBSTR(uc_flammable_liquid, AT("|",uc_flammable_liquid,2)+1,4)="H224" OR SUBSTR(uc_flammable_liquid, AT("|",uc_flammable_liquid,2)+1,4)="H225" OR SUBSTR(uc_flammable_liquid, AT("|",uc_flammable_liquid,2)+1,4)="H226" OR SUBSTR(uc_flammable_liquid, AT("|",uc_flammable_liquid,2)+1,4)="H227" OR SUBSTR(u_oxidizing_liquids, AT("|",u_oxidizing_liquids,2)+1,4)="H271" OR SUBSTR(u_oxidizing_liquids, AT("|",u_oxidizing_liquids,2)+1,4)="H272" OR SUBSTR(u_oxidizing_Solids, AT("|",u_oxidizing_Solids,2)+1,4)="H271" OR SUBSTR(u_oxidizing_Solids, AT("|",u_oxidizing_Solids,2)+1,4)="H272" , gu_P210 + CHR(13) + CHR(10), "") +

The expression above looks to see if any of the classifications have the hazard code and if they do, then precautionary statement P210 will print on the SDS. There is one of these IIF statements for every precautionary statement that is set up in System Constants.

Section 3: Composition/Information on Ingredients

Section 3 has a very simple setup in order to print all regulatory/Raw Materials, their CAS number, and percent of composition without giving away trade secrets or the actual composition amount.

The chemical name for each regulatory/Raw Material can be printed on the GHS/SDS by selecting Block Type: Table on the Edit Field form in the Report Designer and adding an expression similar to the one below.

  • IIF(pr_hazflag = 1, ALLT(pr_descrip),'')

The conditions in which it prints can be altered. For example, only print when it is hazardous and is a trade secret. The block types are used to report data from another table, in SDS this would be the lowest level of the Formula, regulatory, or Raw Material. By choosing this block type, the user will get a clean list of the components that are in the finished product printed on the SDS. This same method would then be used to print the percentages of the component and the CAS#. When the SDS is printed, all three fields will be printed for each component in a table like format.

Printing Data from a Finished Good User Field

Printing data from a Finished Good is as simple as adding the User Field to the form itself, however, most of the time there is a static statement and additional information that is added to the end. Using the example below for First Aid Eyes, the text "Immediately rinse eyes with running water for a minimum of 15 minutes." Would always print on the SDS and anything that is entered into the User Field on the Item Master would be added to the end of the statement. It is not a requirement to display text this way but is the most common approach.

  • "Immediately rinse eyes with running water for a minimum of 15 minutes." + " " + u_eye_1stAid

Designing the GHS form

GHS Labels contain most if not all of the information from Section 2 and sometimes will display information from additional sections of the SDS, such as first aid measures or extinguishing measures. The expressions from the SDS are copied over to the GHS during implementation and formatted slightly based on how they should display. For example, on the SDS the precautionary code should display but on the GHS it is not needed and it is a paragraph rather than printing one statement per line.

Modifying the Part Form in DEACOM

SDS/GHS Forms are integrated into the DEACOM system using Part Forms which in turn utilize MS Word (in classic) or the Report Designer (in web). A basic overview of the process is indicated in the steps below. Complete information on the creation and setup of part forms is available via Managing Part Forms.

  1. Navigate to Print Outs > Maintenance > Part Forms and create a new Part Form for the SDS. A few examples of SDS sections created in DEACOM are provided further down on this page.
  2. Once the SDS Part Form has been created, the form needs to be assigned in the DEACOM system, first to the Inventory Options and possibly on individual Item Masters or Customer Part Cross References, if required.

Note: Deacom consultants are available to help set up the SDS functionality in DEACOM. The consultants will help with creating the Part Forms and setting up the data to meet the exact customer specifications. The consulting costs associated with this are usually cheaper than looking for another software system to integrate with.

Once SDS/GHS Part Forms are created they may be assigned to the appropriate level or hierarchy within DEACOM. The following hierarchy is available:

  • System Level - An SDS part form is indicated on the "Part Forms" tab within Inventory Options and is used when printing SDS forms unless an SDS form is specifically specified on the individual Item Master.
  • Item Master Level - An SDS part form is indicated on the "Part Forms" tab within Inventory > Item Master and is used when printing SDS forms where the specific part is used.
  • Customer Part Level - An SDS part form is indicated on the customer part record via the "Bill-to/Ship-to’s" button within Inventory > Item Master and is used when printing SDS forms where the specific customer part is used.

Note: Customers may have SDS forms at all three levels if necessary. The concept is that the SDS form assigned at the system level will be the universal form with SDS forms assigned at the item master or customer item specific level where exceptions or special cases apply.

Printing GHS labels and SDS forms

GHS Labels and SDS forms can be printed in multiple places within the DEACOM software. GHS Labels can be printed before or during finishing a Job through the Job labels feature. Clicking the "Job Labels" button after creating a Job will allow the user to pre-print the label and checking the "Print Job Labels After Finish" flag during Input Production will let the user print as finishing is performed. The labels can also be printed as Sales Order labels at either the order detail level or during shipment. Normally GHS Labels are printed during production.

SDS forms can be printed ad-hoc via Print Outs > SDS Forms. From here, select the Part and Formula and then click "Print". SDS can also be printed through Document Groups before or during shipping, and finally customer specific SDS forms can be assigned through Customer Part Cross References that can be printed before or during shipping.

Using 3E Generate

3E Generate, formally known as MSDgen, automates the authoring of labels and SDS forms through the use of SQL triggers in DEACOM to send the information down to 3E Generate. This occurs during the Input Production transaction to create a GHS label and during the shipment process to create an updated GHS label and SDS form based on the destination country.

The DEACOM solution outlined is tremendous if little international shipment is done and if not constantly sourcing new Raw Materials. However, the 3E Generate solution is a good way to go if the company does not fit in this mold. 3E Generate is not cheap which is why it is not a good fit for everyone.

Deacom consultants are available to help set up the SDS functionality in DEACOM when using the 3E Generate™. The consultants will help with creating the Part Forms and setting up the data to meet the exact customer specifications. The consulting costs associated with this are usually cheaper than looking for another software system to integrate with.

Example: Basic SDS form

As indicated previously, a typical SDS may contain as many as 16 sections, in some cases even more. The examples below are taken from a few specific sections of an SDS form.

SDS Section 1: Product and Company Identification
  • Company Name: 16824 Park Circle Drive, Chagrin Falls, Ohio 44022
  • Company Phone Number:
  • Emergency Phone Number:
  • CHEMTREC Phone Number:
  • Product Name: <<pr_descrip>> - *indicates the DEACOM item description
  • Product Number: <<pr_codenum>> - *indicates the DEACOM part number
  • Issue Date: <<date()>> - *This code signifies today’s date
  • Supersedes Date: <<re_lastrev>> - *This code signifies the last time someone updated the BOM — for the finished good in this case
SDS Section 3: Composition/information on ingredients

INGREDIENTS CAS# WEIGHT%

<<TABLE=IIF(U_HAZARDOUS = .T. AND 1.00<totwgt/VAL(STRTRAN(u_totwgt,”,”))*100, PADR(u_msdsname, 22)+ PADR(u_casno, 15) + PADR(IIF(BETWEEN(totwgt / VAL(STRTRAN(u_totwgt,',')), .01, .05), "1 - 5%", IIF(BETWEEN(totwgt / VAL(STRTRAN(u_totwgt,',')), .05, .20), "5 - 20%", IIF(BETWEEN(totwgt / VAL(STRTRAN(u_totwgt,',')), .20, .50), "20 - 50%", IIF(BETWEEN(totwgt / VAL(STRTRAN(u_totwgt,',')), .50, 1), "50 - 100%", "< 1%")))), 14), “ ”)>>

The words INGREDIENT, CAS#, and WEIGHT% represent the column headers for the table that will be populated as a result of the "TABLE" function or tag that is used on the part from.

In this example, the code begins with the “TABLE” function – reviews every part in the regulatory BOM and if on any of the materials in the BOM if the user field u_hazardous is marked “yes” and if the weight % of this material is more than 1.00% of the total weight of the sum then valuate the weight % and if it is between .01 and .05 then return the text “1-5%” etc……

Note: BOM line user fields may be used within the TABLE tag when printing SDS forms

FAQ & Diagnostic Tips

Tip: You will not be able to create a SDS PDF, or email, if the part number contains a forward slash. PDF files do not allow a forward slash in their file names.

The incorrect SDS Form is printing for an Item, why?

Check the part form assignment on the item in the Item Master > Modify the Part > Part Forms tab > SDS assignment. If this is blank, the SDS designated in Inventory Options is being used.

Can 3E Generate be used to create and maintain SDS and GHS Forms?

Yes, the process of creating and maintaining SDS forms via 3E Generate® involves the use of SQL triggers. As indicated previously, DEACOM’s configurable part forms are flexible enough to support GHS labels and SDS sheets. However, if customers wish to use the third party software provided by 3E Generate®, Deacom has built an interface with 3E Generate® to sync all formula changes, shipments and job completions in order to generated the required GHS documentation. The 3E Generate® may benefit customers who constantly change formulations and ship outside the US. The creation and maintenance of the SQL triggers is handled via the MS SQL Server Management Studio software and the trigger itself is setup on the DEACOM system table containing the appropriate information via the "Triggers" folder.

Note: Deacom consultants are available to help set up the SDS functionality in DEACOM when using the 3E Generate®. The consultants will help with creating the part forms and setting up the data to meet the exact customer specifications. The consulting costs associated with this are usually cheaper than looking for another software system to integrate with.

Can I print quality control information from the BOM revision on an SDS Form?

Yes. SDS forms can be configured to include QC information from the QC Group(s) assigned to BOM revisions. To accomplish this, the SDS form must contain a field with the QCINFO block specified and a valid QCINFO expression. An example of an expression would be: "ALLT(qc_name) + "; " + ALLT(q3_name) + "; " + ALLT(q2_name) + "; " + TRANS(q2_min) + "; " + TRANS(q2_max)") Once this has been completed users will need to select a revision when printing SDS forms via Print Out > SDS Forms.