...is a term which all environmentally conscious companies are eager to demonstrate.

All responsible companies have to ensure that when they use hazardous materials in their plant operations or in the production of their finished products, they can produce documented evidence to show they have not polluted, by their negligence:

The Air that we breathe,

The Water that we drink, the fish that we eat, or the sea and rivers that we swim in,

The Soil that we use to grow our food, or build our houses on or the fields that our children play on.

To achieve these objectives companies are obliged by law to apply stringent methods of control and compliance. This article explains the issues that relate to meeting compliance regulations and how information technology is helping companies meet these requirements.

User Requirements
When a company uses a chemical in any part of their production they have to create a document called a Material Safety Data Sheet (MSDS). The MSDS accompanies the product when it is sold and is usually produced when the finished goods are manufactured or selected for distribution and delivery. The goods that are generally applicable are Raw Chemicals, Petrol, Oil, Paints, Solvents, Glues, Inks and Pharmaceuticals and are also applicable to products that come in contact with Food, Skin, Air, Sea, and Eyes. A number of examples where this is perhaps not so obvious is the Ink that is used on a Mars Bar wrapper, the Ink has to be qualified and a New MSDS produced on the production of each New batch. The solvent that resides in a can of Coca-Cola that separates the Coke from the can also requires a New MSDS every time a new batch is created.

Conversely, whenever a company receives raw materials that contain hazardous chemicals, they are obliged by law to produce a COSHH (Control of Substances Hazardous to Health) document. This document is to ensure that their employees who will work with the raw materials know how to work with and deal with the materials should there be any accidents while they are using them, (this is often called "the right to know").

Where substances are particularly harmful, companies employ their own chemists who analyze the products they receive and produce new documents that comply with COSHH standards.

Almost all companies now insist upon an MSDS on their receipt of the products. Should an MSDS not accompany the products, the products are likely to be refused entry at the factory gates. Similarly when companies produce their own products and if the product has been manufactured using hazardous chemicals or is itself hazardous, the company has to produce a MSDS and hazardous Label before shipment can be made. If the product, which they are producing, is a NEW product they have to generate a NEW MSDS and a Hazardous Label which will accompany the goods until they reach their destination.

There are 16 different sections to an MSDS document.
The sections include: The Product Name, Product Code, Intended use, Composition, (listing chemicals used), the risks associated with its use, the toxicity, the medical affects, the aggravations it may cause, the long term effects to exposure, first aid remedies, fire precautions, combustion special protection, cleaning, storage, handling, Physical & Chemical Data, Stability and Reactivity, Ecological Information, Disposal Information, Transportation and Regulatory Information.

In addition to the MSDS, companies are also obliged to produce a Hazardous Label when transporting the goods via rail, Road, Sea or Air. The Labels again have to conform to recognized standards and contain visible logos, which depict the type of hazardous substances and show the same information as the MSDS. They should also reflect the local legislation applicable to the countries that the goods are being shipped through and to; all containers are subject to verification and acceptance by customs officers.

Information System Requirements
The MSDS and Hazardous Label are often produced by different systems and do not share the same data source. An effective Environmental Management System (EMS) takes into account changing workflow patterns, and where possible, uses data already collected from normal business operations and apply this information to regulatory compliance documentation.

As a result, it is important to interface an EMS to a company's Enterprise Resource System (ERP). The software will automatically extract the data from the Order Processing or Bill of Materials application and generate the MSDS and the Hazardous Label from the same source. Other interfaces include data from inventory transaction history for reports that account for material usage, and factory floor transactions that identify such information as lot and product number. Finally, many companies require interfaces to purchasing and/or receiving in order to track these hazardous materials as they arrive at the plant site.

Information Technology organizations will want the ability to interact with standard commercial databases such as Oracle, SQL Server or Sybase. Thus, an EMS system becomes an integrated part of the overall enterprise system implementation. With the advent of e-commerce, an effective system will also make this technology work for the environmental compliance professional.

Record Keeping
The history of each MSDS is maintained and a database in of all the formulations and recipes that a company uses. All updates to chemicals are provided on a quarterly basis and included as part of the system software contains approximately 2400 standard phrases. In addition all EU (CHIP) risk and safety phrases, including the combination Risk and Safety phrases and the additional risk and safety phrases required by Sweden. The list of 2400 standard phrases were developed from three sources:

1. The ANSI (American National Standards Institute) / CMA (Chemical Manufacturers Association) list of recommended standard phrases.

2. The National Institutes of Health, National Library of Medicine, Hazardous Substances Data Bank phrases used to create their chemical data records.

3. Manufacturer MSDS.

Phrases were chosen to accommodate all of the 16 sections of the US CMA/ANSI MSDS and the EU Safety Data Sheet. Also, phrases were chosen and edited to ensure that phrase language is consistent from section-to-section in the MSDS. For example, for a given eye hazard statement in Section 3, complementary phrases exist for Section 4 (First Aid), Section 6 (Spill Response Equipment), Section 7 (Handling), Section 8 (Protection), Section 3 (Emergency Overview), and label phrases.

Adding and translating new phases within our system is an easy task.

The Hazox EMS
Hazox, a software developer who specializes in developing software for the management of MSDS documents, Hazardous Labels and Chemical Reports has been developing Environmental software since 1983. To date their software has direct interfaces with many of the standard ERP solutions from companies like Computer Associates (PRMS), Intentia (Movex), JD Edwards), Marcam (PRISM), SAP, and SSA (BPCS).

EU Regulations:
Classification: The Hazox software incorporates all aspects of Directive 67/548/EEC and subsequent Directives. Hazox Safety Data Sheets comply with the International Standard, ISO 11014-1. Selective Directives include:

88/379/EEC Base Dangerous Preparations Directives

91/155/EEC First Safety Data Sheet Directive

93/112/EEC Directive amending the 91/155/EC

Hazox continually monitors the European regulations for changes, for example, the status of the proposed Dangerous Preparations Directive, 96/C283/01.

The Hazox database includes "Annex I," the classification of components. This is the classification found in CHIP 96. The system also includes the complete logic to determine the classification of preparations, as outlined in the preparation directives. The user can also enter self-classification information. This user-entered classification data is available to the preparation classification algorithm. In addition to the base EU classification, the additional Swedish phrases, symbol, and component classifications are included along with Annex I.

Exposure Limits and Hazard Data: Hazox integrates a regulatory database in addition to Annex I classification information. The following is a sample of data and/or lists:

UK Carcinogens, Maximum Exposure Limits, Occupational Exposure Standards.

IARC classifications

Inventory - EINECS

European List of Notified Chemical Substances

EU No longer Polymers List

EU Dangerous Substances - Classification, Concentration Limits, Labels

UK Substances in Review

German (DFG) MAK Values, Peak Limitations, Carcinogens, Skin/Sensitizers, Chemicals that impact Pregnancy

Inventory Status: The status of a chemical with respect to the EU Inventory (EINECS) is fully integrated through our regulatory database. This database includes all known regulatory inventories.

Languages Supported: English, French, German, Swedish, Dutch, Italian, Spanish, Danish, Norwegian, Japanese, Korean and Chinese are supported. The system is written as a 32-bit application and also supports the Pacific Rim characters. In addition, the risk and safety phrases are available in all ten (10) EU languages. Creating foreign language documents is quite simple. Hazox supplies phrases and (M)SDS templates in the required languages. The user works in their native language and requests the desired language; the system automatically generates the documents in all appropriate languages. The system compiles the foreign language document(s) in parallel with the native language document by finding the appropriate foreign language phrases and templates that differ from the native language through a language code.

Multi-language documents and labels are also easily created. The user can create a "language" code that is associated with phrases containing multiple languages.

The Hazox Dispatch module interfaces to most ERP systems including SAP and BPCS and determines the destination country for a given shipment. The (M)SDSs of the appropriate language(s) are automatically created for the order based on a user-defined table. For example, a shipment to Canada can result in both and English and a French Canadian language (M)SDS being sent.

Algorithms and Rules: The Hazox software incorporates a sophisticated set of rules and program capability. All such rules and programs are user-definable. Our module Ready-Set-Go pre-defines rules and programs that will satisfy most, if not all requirements. The following are examples of rules and programs:

EU calculator - This is compliant with the EU DPD.

Formulation Field Algorithm. The user can tailor the properties of each field of data.

The key features of the algorithm are:

Source level

Inclusion %

Display level

This feature allows the system to generate product level values based on a review and comparison of values for components (mixtures or pure chemicals). For example, the low flash point of all components exceeding a specific % by weight can be selected or chosen to be presented for the product. The system is also able to pick the most severe phrase from all phrases contributed by components of a product and place that phrase on the (M)SDS. This is a very abbreviated sampling of the formulation field algorithms.

Calculations - The user can define simple algebraic and more complex program language calculations. This feature can be used to convert from degrees Celsius to degrees Fahrenheit, as a simple example.

User Functions - These are programs written by Hazox or the user to perform more complex math. For example, the average of values for all components of a complex mixture is calculated and also can be normalised to 100% in the case of missing values for components.

Reference fields and Tables: Relationships between fields can be created using reference fields and tables. For example, First Aid phrases can be related to Health Hazard phrases. The user simply picks a health hazard phrase and the system will automatically pick a pre-defined First Aid phrase. This feature ensures that sections of the (M)SDS contain consistent, not contradictory language. The Hazox solution is used by many large companies worldwide that use IBM's AS/400 to process their orders. More recently Hazox have developed a Client Server solution that uses the Windows NT Server and announced a Web Browser feature that makes the Hazox solution e-commerce capable for use over the Internet or Intranet. The new Web feature allows companies to make available to their customers the MSDS information that is applicable to the products which they sell to them, thereby increasing customer service and improving customer efficiency.

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