Author Archives: Kal

About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.

The New RoHS

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In RoHS news, the real news is that the RoHS2 is really just RoHS.  We still hear people talking about “RoHS2” and “RoHS Recast”  — and there is simply no such thing:  there is just RoHS.  Yes, there were significant updates to the EU Directive that Restricts Hazardous Substances.  That process occurred over the past year.  Amendments to RoHS have been incorporated into RoHS itself.  So the terms “RoHS recast” and “RoHS2” have no meaning.

RoHS right now. Over the past year, the ban on heavy metals and other dangerous chemicals in electrical and electronic equipment has been extended to a much wider range of products. The changes apply to electronic products such as thermostats, medical devices and control panels.

European Member States have until the end of 2012 to transpose the new rules.  This means most will wait until the last minute (and beyond), but some will not, and to an American mind the order and timing will seem somewhat random.  Since there is no orderly way to hedge your bets here, getting to RoHS compliance in Q1 2012 or (Q2 at the latest) is the path of least risk.

The RoHS Directive will continue to ban lead, mercury, cadmium, hexavalent chromium and the flame retardants Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE). The previous RoHS Directive covered several categories of electrical and electronic equipment including household appliances, IT and consumer equipment, but RoHS has now been extended to all electronic equipment, cables and spare parts.  Exemptions can still be granted in cases where no satisfactory alternative is available.

Updates to RoHS.

  •  A gradual extension of the rules to all electrical and electronic equipment (EEE), cables and spare parts, with a view to full compliance by 2019
  •  A review of the list of banned substances by July 2014, and periodically thereafter
  •  Clearer and more transparent rules for granting exemptions from the substance ban
  •  Improved coherence with the REACH Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals
  •  Clarification of important definitions
  •  CE marking denoting compliance with European norms reserved for electronic products that also respect RoHS requirements

In view of the significant extension of the scope, the new Directive introduces transition periods of up to 8 years for the new products affected by the rules.

Photovoltaic panels are exempted from the new Directive in an effort to help the EU reach its objectives for renewable energy and energy efficiency.  Also included in the new RoHS is a mechanism to make it easier for the Commission to monitor compliance.

RoHS2 background. The revision was launched in 2008. Agreement between the European Parliament and the Council was reached in 2010 and the Directive was adopted in June 2011. Member States have 18 months to transpose the Directive. Until then, RoHS I continues to apply.

Detailed information can be found in the directive here.  See also the Europa.eu site on waste and RoHS.

RoHS is a directive, not a regulation:  A directive is about results, not process.  With RoHS for example, the required result is the restricted use of certain toxic metals in electronics manufacturing & in related disposal and waste.  A regulation, on the other hand, delineates how to get the result, a good example being the REACH regulation, which contains a detailed process for substance registration, use, and data sharing.

This blog is hesitant to recommend specific consultants for RoHS compliance.  However, some software for RoHS compliance such as Material Disclosure from Actio Corp., is worth looking at for RoHS compliance.

Canadian Chemical Regulations: An View From Above

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Quality professionals focus on Europe, the US and even China — as with China REACH and China RoHS for example — when we speak of chemical regulations.  Sometimes we overlook Canada when we say “global.”

This is a mistake. Many supply chains go through Canada, and Canadian substance-level regulations are not shrinking violets at the regulatory compliance dance.

One really good way to stay on top of Canadian environmental law is to read the annual Blake’s Guide to Environmental Law in Canada. The document is an effective introduction to the principal laws and regulations in Canada and the provinces of British Columbia, Alberta, Quebec and Ontario, concerning environmental protection and conservation.

Specific advice should be sought in connection with particular matters or transactions — questions can be routed to the authors of this blog or to the environmental lawyers listed in the guide.

Key subjects include:

  1. Canadian Environmental Protection Act, 1999 (CEPA)
  2. Canadian Environmental Assessment Act (CEAA)
  3. Transportation of Dangerous Goods Act, 1992 (TDGA)
  4. Hazardous Products Act (HPA) and Canada Consumer Product Safety Act (CCPSA)
  5. Pest Control Products Act, 2002 (PCPA)
  6. Fisheries Act
  7. Canada Shipping Act
  8. Marine Liability Act
  9. Navigable Waters Protection Act (NWPA)
  10. Oceans Act
  11. Canada National Marine Conservation Areas Act
  12. Species at Risk Act (SARA)
  13. Migratory Birds Convention Act, 1994 (MBCA)
  14. Canada National Parks Act
  15. Criminal Law
  16. Energy Efficiency Act

The Canadian law firm Blake, Cassels & Graydon LLP has issued Blake’s Guide to Environmental Law in Canada.

The guide also provides an overview of environmental law in Ontario, Quebec, Alberta, and British Columbia.

Canadian law and toxic substances. CEPA, the Canadian EPA, provides the federal government with “cradle to grave” regulatory authority over substances considered toxic. CEPA provides for assessment of “new” substances not included on the Domestic Substances List, a national inventory of chemical and biotechnical substances.

It’s required that an importer or manufacturer must notify the federal government of a new substance before manufacture or importation can take place in Canada. Consequently, businesses must build in a sufficient lead-time for the introduction of new chemicals or biotechnology products into the Canadian marketplace. In certain circumstances, manufacturers and importers must also report new activities involving approved new substances so they can be re-evaluated.

All existing substances included on the Domestic Substances List are in the process of being
assessed by Environment Canada for bioaccumulation, persistence and inherent toxicity
(BPIT). Currently, Environment Canada is in the process of collecting information and
conducting risk assessments with respect to a series of “Batches” as part of the “Challenge to Industry” program.

Under the Canadian Environmental Protection Act, a substance is “toxic” if it is entering or may enter the environment in a quantity or concentration or under conditions that;

  1. have or may have an immediate or long-term harmful effect on the environment or its biological diversity
  2. constitute or may constitute a danger to the environment on which life depends or
  3. constitute or may constitute a danger in Canada to human life or health

Substances that are persistent, bioaccumulative, and result primarily from human activity
must be placed on the Virtual Elimination List. Listed toxic substances include:

  1. PCBs
  2. CFCs
  3. chlorinated solvents

You can contact us or contact the Blakes, a law firm that regularly produces reports and special publications on Canadian legal developments. For further information about these reports and publications, please visit blakes.com.

TSCA Update: New Chemical Reporting for 2012

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Last week the US Environmental Protection Agency held a training session to further explain the amendments to the Toxic Substances Control Act (TSCA), scheduled for 3 hours this afternoon.  For those who couldn’t make it, here’s the distilled version:

For starters, there is a section 8(a) Inventory Update Reporting (IUR) rule change in name, to the Chemical Data Reporting (CDR) rule.  The new name is more precise, we appreciate that.   “Inventory” is a softer word than “chemical” but it has also far too broad an implication in the industrial world.

EPA is promulgating several amendments to the IUR / CDR rule, taking into consideration comments received on the proposed rule.  The amendments were proposed in the Federal Register issue of August 13, 2010.

In short, the way Production Volumes are reported will change:

*

Who is affected? Businesses are affected by this action if they manufacture (including manufacture as a byproduct or import) for commercial purposes chemical substances listed on the TSCA Inventory and produced in volumes of 25,000 lb or more during the principal reporting year (i.e., calendar year 2011).

Potentially affected entities likely include but are not limited to:

  1. Chemical substance manufacturers and importers (North American Industry Classification System (NAICS) code 325 and 324110; e.g., chemical substance manufacturing and processing and petroleum refineries)
  2. Chemical substance users and processors who may manufacture a byproduct chemical substance (NAICS codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, and semiconductor and other electronic component manufacturing)

In short:  manufacturers — including importers — of TSCA Inventory-listed chemical substances with a 2011 production volume of 25,000 lb or greater at a site, unless otherwise exempted.

The 2012 submission period is Feb. 1 to June 30, 2012. You need to know:

  • Reporting is site-specific
  • Reporting standard is “known to or reasonably ascertainable by” for all data
  • CBI – upfront substantiation required for:
    • Site and chemical identity claims
    • Processing and use information claims [new requirement]

Manufacturing-related data includes:

  1. Chemical identity
    1. CAS RN and chemical name
    2. Accession number and generic chemical name for CBI substances
  2. Production volume (PV)
  3. Number of workers that are reasonably likely to be exposed (in ranges)
  4. Maximum concentration
  5. Indication of whether a manufactured chemical substance is being recycled, remanufactured, reprocessed or reused
  6. Physical form and percent production volume in the form
  7. Processing and use-related data are required for production volumes of 100,000 lb. or more, at a site, unless otherwise exempted

Online web based software can help with the new reporting requirements.  EPA has offered up a web based portal of similar nature.

*chart courtesy EPA CDR training info

 

REACH Database: Over 5000 Substances Registered

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The European Chemicals Agency (ECHA) announced Wednesday that ECHA’s Dissemination Database contains now 4413 records. In total, 5181 substances have been registered as of Nov. 3, 2011, says the agency.

There are now 3908 substances published on the list of registered publishable substances.

On ECHA’s dissemination portal, you can download information or search for substances; an excellent resource for folks looking more deeply into REACH compliance.

The next big REACH deadline is May, 2013, but ECHA is asking companies to start preparing now.

En route to the 2013 deadline, there are two key deadlines for 2012:

1. Late preregistration deadline prior to the 2013 registration deadline, for first time manufacturers and importers;

2. Downstream users should notify suppliers of uses by May 31, 2012 at the latest.

Proper Etiquette: California Prop 65

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California’s chemical law known as Proposition 65 requires the state to publish a list of chemicals known to cause cancer or birth defects or other reproductive harm.  The Prop 65 list was first published in 1987.

The list was updated on Oct. 28. The latest chemical added is tris(1,3-dichloro-2-propyl) phosphate (TDCPP).

Businesses have one year to organize warning and labeling systems if manufacturing or selling products in California that contain this chemical.  What does a label look like?

Here is a sample label under Prop 65.

(That particular label makes you think, doesn’t it?  It made me think..!)

At the end of this post is a current list of chemicals on the Prop 65 list. Scroll down to that section if desired, and download the list in PDF form, to keep for your records.

What is Prop 65?  California Prop 65 is actually the “Safe Drinking Water and Toxic Enforcement Act of 1986.”  It manifests as a list of chemicals known to the state of California to cause either cancer or reproductive toxicity.  The list:

  1. must be updated at least once a year
  2. products and facilities containing these chemicals are asked to clearly post warnings indicating the presence of these chemicals
  3. must be published for all to see

The Prop 65 list currently includes approximately 800 chemicals.

Now, included on the Prop 65 list are things we sometimes think of as benign, such as alcohol and aspirin.  Alcohol makes the list because it obviously can be toxic in sufficient amounts.  Aspirin makes the list because it has been shown to cause reproductive harm in fetuses if ingested by women in advanced stages of pregnancy.

So not all 800 chemicals on the Prop 65 list should be avoided at all costs (and in some cases they might save your life, as with aspirin to thin the blood, or, arguably, alcohol to get through holidays with the in-laws).  The important thing is that even if a chemical is safe for you, it might not be safe for others; some chemicals, eerily, do not seem to harm women at all but mess with the male developmental system in undesirable ways.

And, while a chemical may be safe for some uses, it may be toxic in certain doses, or in other uses, or for another gender.  The Prop 65 list seeks to publish the identity of every chemical that can be a danger.

Requirements for business under Prop 65. All chemicals on the Prop 65 list require businesses to act in some way, typically by posting a warning in the workplace, or by affixing a label on a product that contains, say, a globally-regulated toxin such as cadmium (which is also on the list).

Again, to see an ironic sample Prop 65 label, click here:  toxic breast cancer ribbon.  There you will see one of the great ironies of modern culture, and also the reason I look forward to coming to work in the morning.  The link goes to the image of a Fight Breast Cancer pink ribbon that you pin on your shirt, the packaging bears a warning that the ribbon itself contains chemicals that are known to cause cancer.

For those that don’t know, besides being a practicing CIH and Professional Chemical Engineer, I cofounded a company 15 years ago that provides manufacturers with software for tracking chemical ingredients from suppliers.  This type of software, the hope is, will maybe one day eradicate the need for such “ironic” labels on a Fight Cancer ribbon, because greener, non-toxic alternatives have been identified and used.

Warnings and labels under Prop 65. Businesses are required to provide a “clear and reasonable” warning before knowingly and intentionally exposing anyone to a listed chemical. This warning can be given by a variety of means, such as by labeling a consumer product, posting signs at the workplace, distributing notices at a rental housing complex, or publishing notices in a newspaper. Once a chemical is listed, businesses have 12 months to comply with warning requirements.

Proposition 65 also prohibits companies that do business within California from knowingly discharging listed chemicals into sources of drinking water. Once a chemical is listed, businesses have 20 months to comply with the discharge prohibition.

Exemptions. Businesses with fewer than 10 employees and government agencies are exempt from Proposition 65’s warning requirements and prohibition on discharges into drinking water sources. Businesses are also exempt from the warning requirement and discharge prohibition if the exposures they cause are so low as to create no significant risk of cancer or birth defects or other reproductive harm.

Risk thresholds. For chemicals that are listed as causing cancer, the “no significant risk level” is defined as the level of exposure that would result in not more than one excess case of cancer in 100,000 individuals exposed to the chemical over a 70-year lifetime. In other words, a person exposed to the chemical at the “no significant risk level” for 70 years would not have more than a “one in 100,000” chance of developing cancer as a result of that exposure.

CA Prop 65 “safe harbor numbers.” OEHHA develops numerical guidance levels, known as “safe harbor numbers,” for determining whether a warning is necessary or whether discharges of a chemical into drinking water sources are prohibited.

However, a business may choose to provide a warning simply based on its knowledge, or assumption, about the presence of a listed chemical without attempting to evaluate the levels of exposure.

Businesses do not file reports with OEHHA regarding what warnings they have issued and why, on that basis, or because of that, OEHHA is not able to provide further information about any particular warning, which is unfortunate. Instead, contact the business issuing the warning.

Enforcement and penalties. The California Attorney General’s Office enforces Proposition 65. Also, any district attorney or city attorney (for cities whose population exceeds 750,000) may enforce Proposition 65. So can an individual acting in “public interest” may enforce Proposition 65 by filing a lawsuit against a business alleged to be in violation.

Lawsuits have been filed by the Attorney General’s Office, district attorneys, consumer advocacy groups, and private citizens and law firms.  For enforcement information, contact the California Attorney General’s Office at (510) 622-2160 or visit http://ag.ca.gov/prop65/

Penalties for violating Proposition 65 go up to $2,500 per violation per day if businesses fail to provide notices.

For more information on the Proposition 65 list of chemicals, contact OEHHA’s Proposition 65 program at (916) 445-6900, or visit oehha.ca.gov/prop65.html.

Download the list of chemicals on California’s Prop 65 list, no registration required.  Be advised there are 23 pages of this list; below is a snapshot of just the first page.  This list was updated Oct. 28. It’s a good document to download and keep for your records.

The Next Big REACH Deadline

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The European Chemicals Agency (ECHA) recently launched a campaign to remind industry to start preparing for the second REACH registration deadline, as reported by REACHspot.  We put together a few guidelines on how to prepare for the next round of REACH regulation deadlines.  Really, the next one to worry about is May of 2012.  Here’s what you need to know.

The big REACH deadline in 2013.To prepare for the REACH 2013 deadline, companies manufacturing or importing chemicals in Europe — in quantities at or above 100 tonnes per year — are required to register such substances with ECHA by May 31, 2013.

But first, find out if your substances are already registered.  To do this, simply go to the ECHA database of registered substances and search for your chemical.

If your substance meets the criteria of passing through the EU at a quantity of 100 tonnes or above and it has not already been registered, you are required to register your substance.

How to compile information to register. There are a few elements involved in compiling necessary information for registration.

  1. Substance identification and sameness of substance: confirm with the other preregistrants that you have the same substance
  2. Hazard information: collect all data available on the intrinsic properties of the substance to be registered
  3. Data sharing: as part of a joint registration, gather and share existing information, consider alternatives to testing and answer any information request from within your Substance Information Exchange Forum or SIEF
  4. Chemical safety assessment: carry out a chemical safety assessment in order to produce a chemical safety report based on the hazard information collected and knowledge on the uses

To wit:  for joint submissions, there must be a  so-called Lead Registrant who, yes, leads — and Members who follow.  The Lead Registrant is one registrant acting with the agreement of the other assenting registrant(s) who will submit the joint registration dossier with all information. ECHA recommends this is done at least 2 months before the legal deadline, which means by March 31, 2013. Members are other registrants who have confirmed their membership in the Joint Submission in REACH-IT, they have to submit their registration after the Lead Registrant within the May 31, 2013 deadline.

REACH deadlines 2012.There are 2 key deadlines for May of next year.

  1. Late preregistration deadline prior to the 2013 registration deadline, for first time manufacturers and importers. Late preregistration is a simple process. You just submit your information, via an agent, your own internal REACH software, or online using REACH-IT.  Please note that late preregistration is only allowed under specific circumstances.
  2. Downstream users should notify suppliers of uses by May 31, 2012 at the latest.

You are a downstream user if you use a substance, either on its own or in a mixture — also called a chemical cocktail — in the course of your industrial or professional activities. If you are a manufacturer or an importer of a substance, a distributor or a consumer, you are not a downstream user. Guidance is available.

Also, it’s advised that you research available tools for substance management and REACH management in particular, try a Google search for REACH software to start.

Ecodesign: Meet the New ISO 14006:2011

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ISO has developed a new standard to help organizations efficiently implement “ecodesign” — which is what it sounds like. The goal is for organizations to use the principles of ISO 14006:2011 in order to design and develop more advanced, profitable and sustainable goods and services.

Alongside, the newly published ISO 14006:2011 Environmental Management Systems – Guidelines for Incorporating Ecodesign provides instructional guidance on incorporating ecodesign into any environmental, quality or similar management system. The target audience is industry.

ISO 14006:2011 does not establish by itself specific environmental performance criteria and it is not intended for certification purposes. However, guidelines for incorporating ecodesign gives “how to” guidance on incorporating ecodesign into any environmental, quality or similar management system.

The ISO 14006 standard aims to assist organizations in their management of ecodesign as part of an environmental management system (EMS). Specifically, it aims to help:

  1. Establish.
  2. Document.
  3. Implement.
  4. Maintain.
  5. Continually improve.

Ecodesign. The goal is greener product development and greener product lifecycle management. The guidance applies to those environmental aspects of an organization’s products and/or services over which it has control or influence.

ISO 14006:2011  ISO 14006 is applicable to any organization. It is NOT conditional on a company or entity:

  1. Size.
  2. Geographical location.
  3. Culture.
  4. Complexity of management system(s).
  5. Complexity of target product or service.

The new standard is intended to be used primarily by organizations that have implemented an EMS according to ISO 14001, whether or not they have a quality management system (QMS) according to ISO 9001. It can also be useful for organizations without a formalized EMS or QMS but which are interested in reducing the adverse environmental impacts of their products.

ISO 14006:2011 was developed by ISO technical committee ISO/TC 207, Environmental management, subcommittee SC 1, Environmental management systems, working group WG 4, Guidelines in ecodesign. It may also be obtained directly from the ISO Central Secretariat, price: about USD$135.00 via the ISO Store online.

Other ISO standards of interest  The ISO 14000 family of standards relating to environmental management systems in businesses, homes and communities.

  1. ISO 14006:2011 — Environmental management systems — Guidelines for incorporating ecodesign.
  2. ISO 14005:2010 — Environmental management systems — Guidelines for the phased implementation of an environmental management system, including the use of environmental performance evaluation.
  3. ISO 14004:2004 — Environmental management systems — General guidelines on principles, systems and support techniques.

By complying with ISO 14000 standards, you’re never afraid to show your hand.

Breaking Chains: New California Law Means Supply Chain Audits

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If your business touches the great state of California, you’ll want to know about this new law, effective January 2012.  The California Transparency in Supply Chains Act of 2010 will bring audits of supply chain practices to a new level.  Businesses need to know what’s going on not just here, but over there.

Starting Jan. 1, 2012, if you haven’t scoured every corner of your supply network for possible dark spots, you must be able to show that:

  1. you are capable of a supply chain audit, and
  2. you have procedures, resources and tools in place to regularly execute such an audit, i.e., that you are capable.

Supply chain visibility becomes law. In September 2009, the US Department of Labor released a report that named 122 goods from 58 countries that are believed to be produced by forced labor or child labor in violation of international standards. The State of California then passed a human trafficking law that will take effect Jan. 1, within the law there is an amendment to the state Revenue and Tax Code.  This amendment includes disclosure requirements that will rock the supply chain and make transparency more necessary than ever.

This legality was a subtle part of the umbrella law, and it’s only now that executives are realizing its ramifications.  There’s a related flurry of business for supply chain management software, especially the more cost effective, quick to implement, platform and location agnostic Software as a Service (SaaS) modules.

The new law is also expected to boost sales of headache pharmaceuticals for Supply Chain Managers around the world.

From electronics to organic food. A supply chain in any industry, from electronics to aero and auto, and into food manufacturing and distribution needs to be able to audit its supply chain for sourcing and working conditions.  Consider some of the working conditions in the food industry, for instance, even though the electronics industry gets so much of the attention on this (e.g., Foxconn), not to mention mining, metals and oil & gas.

One good example is illustrated by how IPC, the renowned electronics industry association, points out the new law’s affect on its member companies:

There will be serious consequences for the entire electronics industry: customers will ask questions and supply chains will be audited regarding social responsibility practices, imposing extremely costly burdens. The immediate effect will be on organizations with annual gross global receipts in excess of $100 million, with a set of disclosure requirements that must be clearly publicized on company websites.

How to comply with California’s new law. For more information, ask your quality assurance managers, risk management team and compliance officers to review the law itself, and consider contacting the advisor you trust for supply chain compliance.  There are three key elements of an assurance program:

  1. whether a particular program or software tool can work in your unique business conditions
  2. how quickly it can be implemented
  3. whether the tool can work with your current software platforms/ERP/portal(s)

Good luck to all and to the Golden State.

 

The Leaning Tower of Six Sigma

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Whatever happened to Six Sigma? It was so intently-discussed in years past — then faded from the conference table. Well, it’s back. From the Obama administration’s Oval Office to siloed enterprise facilities in rural areas of America, Six Sigma is a hot topic — again.

What is Lean Six Sigma? Lean emphasizes removing waste from organizations and processes while focusing on and delivering more value to customers. Six Sigma focuses on variation reduction in processes, products, and services. Lean Six Sigma is basically streamlined processes but faster, simpler. (And yes, there’s an app for that.)

Lean Six Sigma has been back in the spotlight recently as several U.S. presidential candidates have pledged to use the management tool, if elected. Also, the Obama administration is reportedly studying how Lean Six Sigma could help eliminate federal government waste.

Lean Six Sigma online survey  More than 2,500 quality improvement professionals participated in a recent survey around the subject of Lean Six Sigma. A group called ASQ conducted the survey, ASQ being a “leading global network of quality experts,” and in all fairness is a reputable organization. It was conducted using online technology, across disparate geographies.

Lean Six Sigma could help reduce the soaring national debt, decided the survey respondents, but it faces some key challenges in government implementations. The biggest obstacle, survey respondents said, is a U.S. federal government structure that can be a barrier to comprehensive evaluation and accountability.

In addition to noting challenges with the federal government’s structure, survey participants noted other obstacles to implementing Lean Six Sigma in government agencies:

  1.     An environment faced with conflicting strategies, goals, and priorities
  2.     Creating a sense of urgency to deploy a comprehensive improvement methodology across all government agencies
  3.     The personnel management model currently used by many government agencies
  4.     A lack of familiarity with Lean Six Sigma and how it can benefit the organization
  5.     Ongoing political partisanship

Lean Six Sigma in Action  “In business, some process improvements are obvious,” said Russell McCann, national speaker on Six Sigma and President and CEO of Actio. “For instance, if a scientist is creating a new product, and the product contains a chemical that is banned or is restricted in some countries, then it’s best to identify the issues at the request stage.  This averts a scenario where the enterprise spends millions of dollars developing an unusable product.

“While these sorts of process improvements can be done manually – with traditional paper-based systems – process efficiency and accuracy are compromised,” said McCann.  “Critical information is inevitably ‘siloed’ at individual locations rather than being shared across an enterprise; in some cases data is not even shared within a single facility.  This type of scenario presents an ideal environment for a Six Sigma program.

“A Six Sigma initiative that includes Six Sigma software such as Actio modules will reduce cost, improve control processes, and rationalize materials management,” McCann said.

Survey says…  Many participants in the ASQ survey said there are benefits to using Lean Six Sigma. More than 75% of participants surveyed said they have implemented Lean Six Sigma in their organizations and an impressive 79% said the tool is very effective in improving efficiency and productivity.

The respondents found that Lean Six Sigma has also been effective in the following areas:

  1. Raised levels of quality in their organization (74%)
  2. Reduced costs (73%)
  3. Helped individuals in their organization be competitive in the marketplace or to pursue the organization’s core mission (68%)
  4. Had a positive impact on employee safety (56%)
  5. Improved innovation (46%)

Kudos to ASQ for pulling this data together, certainly an interesting study.  ASQ is headquartered in Milwaukee, Wisconsin, with national service centers in China, India, and Mexico.  Learn more about ASQ’s survey, their members, mission, technologies and training at www.asq.org.

Will GHS affect WHMIS?

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GHS stands for the “Globally Harmonized System of Classification and Labelling of Chemicals.” GHS is a system that defines and classifies the hazards of chemical products, and communicates heath and safety information on labels and material safety data sheets (called Safety Data Sheets, or SDSs, in GHS).  The goal of GHS is to have a universal set of rules for classifying hazards, using the same format and content for labels and safety data sheets (SDS) worldwide.

The Workplace Hazardous Materials Information System (WHMIS) is Canada’s national hazard communication standard.  WHMIS has a complicated implementation, a multi-angled approach coordinated through federal, provincial and territorial legislation. The key elements of the WHMIS system are:

  1. cautionary labelling of containers of WHMIS “controlled products”
  2. the provision of material safety data sheets (MSDSs)
  3. worker education and training programs

Overall, the current roles and responsibilities for suppliers, employers and workers likely will not change in WHMIS after GHS, but there will be some changes.

GHS changes to WHMIS. How chemicals are classified will be affected.  It’s likely that WHMIS legislation will:

  1. adopt all of the major GHS health and physical hazard classes including aspiration hazard and specific target organ toxicity-single exposure. Some sub-categories in GHS may not be adopted. It is unlikely that the environmental hazard classes will be adopted under WHMIS (but this does not exclude that it may be adopted by another government department)
  2. continue to include some hazards that are currently not in the GHS system, but are present in the current WHMIS system – such as biohazardous materials
  3. have more specific names for its hazard classes
  4. combine two WHMIS classes (teratogenicity/embryotoxicity and reproductive toxicity) into one new GHS hazard class called reproductive toxicity

What won’t change in WHMIS under GHS. Suppliers, importers and producers duties will continue to include:

  1.     classifying hazardous products
  2.     preparing labels and SDSs
  3.     providing these elements to customers

Employers must continue to:

  1.     educate and train workers on the hazards and safe use of products
  2.     ensure that hazardous materials are properly labelled
  3.     prepare workplace labels and SDSs as necessary
  4.     provide access for workers to up-to-date SDSs
  5.     ensure appropriate control measures are in place to protect the health and safety of workers

Workers will still:

  1.     participate in WHMIS and chemical safety training programs
  2.     take necessary steps to protect themselves and their coworkers
  3.     participate in identifying and controlling hazards

Hopefully this helps set you set up for GHS.  There are tools and solutions for GHS conversion, and here is a web site reference for all things WHMIS: http://www.ccohs.ca/oshanswers/chemicals/ghs.html.  You can contact me with specific issues.