on 2014 Jan 03 7:59 AM
Hi Guys,
Not sure if this is the right place I can ask such questions, but it's more functional related.
For raw materials we buy from supplier, normally we get their SDS, but more often than not, they do not disclose the full composition. Sometimes, only hazard CAS#, or even says it's trade secret.
So comes my question. In your implementation project, what's the guide line to maintain raw material composition? Do we still maintain them up to 100%, or we only input what we know? How about we use those raw material substance for composition of our own products, say to put them as exact composition based on starting material, and use expert rule to breakdown to pure substance and store in the standard composition, or we manually do this because raw material is unknown for its component.
Thanks!
Request clarification before answering.
Dear John
your topic is quite general and linked to the daily work of the product safety and dangerous goods handling competence centers of a company selling and buying chemical products. Based on internal company specific demands a number of approaches are used (which then do have some effect on maintenance in EHS).
first you need to understand the "legal demands"; based on that in most cases a SDS/MSDS is not suffficient to go on with the "internal work". A number of additional informaiotns are needed which should (and are) collected. In most cases companies have prepared "questionnaires" to deal with this work. These questionnaires are send to the seller and should be send back by them. Content of these questionnaires are questions like:
1.) is the product (and components) TSCA listed?
2.) is the product (and components) CEPA listed?
3.) do the product contain drug precursors or other stuff to create e.g. chemical weapon products
4.) etc.
On the top as well as in US and in europe as mentioned by you it is allowed to use "trade secret names" for components etc. Ok this is legally correct and therefore you need to deal with that.within SAP and there is in most of the cases no chance to make the link to CAS number or similar information
In most of the cases the internal process then try to collect enough information to make sure that you can assign some DG information to the product and some SDS/MSDS information so that you can create e.g an "own" SDS for the sellers product (for internal handling mainly).
Therefore: you can have 100% "nothing" in MSDS/SDS regarding the components (there are enough examples) or you can get some "subinformation" (only thos componenst which do have some hazrads etc.). Based on this normally you will establish specifications (either as REAL_SUB or e.g. PURE_SUB). and maintain the data which you get or collect and the create e.g. Composition informations. Here you need to decide: do I maintain what I have (therefor not 100%) or do you use "dummy" specifications to get the "100%" and if so which information would be stored on the "dummy" spec?
At the end: normally you need to make a chemical analysis of the product to detect the chemical composition and based on that you go on with the maintenance of EHS. But in most cases the information on SDS/MSDS is sufficient enough to e.g. generate an "own" SDS/MSDS for a sales product (if you are only mixing something).
So the topics you are raising are really "daily" business, but not for an IT department but for the product safety department. How to deal with that "problem" is a matter of decision of the company. Therefore there is no "clear" answer possible. I am sorry.
C.B.
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