Getting the Most Out of Your Data
How software automation can increase the efficiency of hazardous material business processes
- By Gregory Swiech
- Feb 01, 2004
Hazardous materials (hazmat) compliance has a significant impact on the product life cycle in every organization that is involved in the use, manufacture or transport of dangerous goods. Developing integrated hazmat processes results in measurable improvements in revenue, costs and performance. Optimizing the use of regulatory data in hazmat processes through software can not only decrease time to market, reduce cost of goods sold and improve customer satisfaction, it also can improve regulatory compliance and safe operations.
Dealing with MSDSs
The main function of a hazmat department at a private sector or public sector facility is ensuring that national and international regulations are met for the classification, packaging, labeling and transport of dangerous goods. However, the results of these activities affect the entire organization. Regulatory documents such as material safety data sheets (MSDSs) must be maintained for each hazardous material used or transported and must be readily accessible to employees. The logistics department requires MSDSs, product label text and transport classification information to produce proper packaging, labeling and shipping documents (bill of lading) for the transport of dangerous goods.
Preparing these regulatory documents for the packaging and transport of dangerous goods has always been a labor intensive process. In many organizations, trained and certified transportation professionals spend a large portion of their time maintaining a library of regulations to author transport documents manually. The global scope of most U.S. organizations requires them to comply with not only the U.S. Department of Transportation regulations (49 Code of Federal Regulations), but also with other national and international regulations. Examples of these regulations include:
- Canadian Transport of Dangerous Goods Regulations (TDG)
- International Maritime Dangerous Goods Code (IMDG)
- International Air Transport Association Dangerous Goods Regulations (IATA)
- European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR)
- Regulations Concerning the Transport of Dangerous Goods on the Rhine (ADNR)
- Regulations Concerning the International Carriage of Dangerous Goods by Rail (RID)
Ever-changing government regulations and increasingly strict enforcement make it more important than ever for producers and transporters of dangerous goods to have access to the most current regulations. Regulatory violations can result in large fines and civil litigation. Failure to maintain a readily accessible archive of MSDSs can result in fines by the Occupational Safety & Health Administration (OSHA) of up to $25,000 per day, per occurrence. OSHA issued a total of $1.3 million in Hazard Communication fines for the 2003 fiscal year. The U.S. Department of Transportation (DOT) has issued fines of up to $27,500 for packaging violations, totaling $1.6 million in 2002.
Many organizations have begun teaming with environment, health and safety (EH&S) data providers to reduce costs and streamline the functions of the EH&S and hazmat departments. These data providers offer a consolidated source of information in formats compatible with different software systems. This allows organizations to benefit from a large staff of experts who focus on identifying regulations, monitoring changes and providing up-to-date data, without having to incur the cost of their salaries or overhead.
Integrating Data with Software Systems
Integratable data elements can include physical, chemical, toxicological and ecotoxicological information, in addition to transport requirements, such as packing instructions, maximum quantities and reportable quantities. Obtaining this data electronically from a centralized repository increases accuracy, simplifies the preparation of regulatory documents and ensures that the transport professional has access to the most current compliance information. While electronic distribution can be achieved through accessing Web-based or CD-ROM subscriptions, it is best utilized when the data is integrated directly into the end user's EH&S system.
Change Management & Impact Analysis
Integrating regulatory information into an EH&S system is only the first step in maintaining usable data. Corporations need a methodical approach for identifying regulatory changes and updating the data that is stored in their system. This process is usually accomplished through a data loader -- a software program that acts as a bridge between the provider's regulatory database and the end user's EH&S system. During the initial data integration, regulatory professionals make decisions about which regulations are important to their unique business. These decisions are then stored in order to expedite future updates. Information will not be passed into the user's system until it has been reviewed and approved. This process allows the professionals to make expert decisions regarding the relevance of the regulatory data to their organization's development, production, handling and transportation processes.
When the information needs to be updated, an efficient data loader will recall the decisions already made and offer a complete view of changed elements by displaying the latest data side-by-side with the information currently stored in the user's EH&S system. The new data can then be reviewed before it is loaded into the EH&S system.
Optimizing with Rules and Phrases
Organizations can further optimize their software systems through rules and phrases. The application of rules and phrases eliminates the need for transport experts to manually author documents, freeing them to focus on true compliance issues rather than routine document generation. Phrases are fixed text statements stored in a database that can be used to populate document templates. This enforces standardization and speeds the authoring process. Phrases can include simple terms such as those used to describe physical form ("liquid," "solid" and "solid wet with solvent"), American National Standards Institute (ANSI) First Aid Statements ("get medical attention" and "wash with soap and water") or European Risk and Safety Phrases ("explosive when dry" and "avoid contact with skin").
Rules are specialized algorithms that automate the authoring process using regulatory data, chemical and physical property data and a multilingual phrase library. When the appropriate data has been determined by the application of rules, a large portion of the MSDS is automatically completed including reportable compositions, hazard identification, first aid measures and regulatory classifications. Rules can also be utilized to determine transport classification information and create regulatory documents, other than MSDSs, such as labels, tremcards, Superfund Amendments and Authorization Act (SARA) 313 reports and inventory update reports. The end result from implementing rules and phrases is consistent and accurate regulatory documents for multiple countries in multiple formats and languages produced in a fraction of the time it would take without automation.
Software automation cannot, however, completely eliminate human intervention. Most dangerous goods are mixtures of several ingredients. Software automation can provide regulatory data, including transport classification, for pure chemicals, but is still not sophisticated enough to provide accurate classifications for mixtures. A trained transport professional must make the final transport classification determination based on the chemical and physical properties of the end product. Even when software automation can provide all of the necessary regulatory data, a qualified professional is still legally required to review and approve the documents.
Impact Beyond EH&S
The information generated in an EH&S system can then be used throughout the organization to gain additional value from the application of integrated data, rules and phrases. An organization can utilize the digital information provided by the hazmat department in other corporate software systems to automatically track dangerous goods throughout the product life cycle. With an optimized system, a sales person can instantly determine if an order can be fulfilled. The use of integrated systems can remove delays due to incorrect documentation and import/export restrictions, while preventing the shipment of incompatible products. Optimization also eliminates the need for manual audits of reporting requirements such as export notifications, volume limitations and global inventory checks. Regular data updates through the EH&S system will alert the corporate system of changes and update documents accordingly.
EH&S systems can be significantly optimized through the use of integrated data, rules and phrases. This automation impacts not only the hazmat department, but the entire organization. Corporations will benefit form improved compliance, decreased time to market, and higher productivity -- improving the overall bottom line.
This article originally appeared in the 02/01/2004 issue of Environmental Protection.
Gregory Swiech is a senior research analyst with Ariel Research Corp. in McLean, Va.