What is GHS and where did it come from?

In 2003 the United Nations Economic and Social Council adopted a globally harmonized system of classification and labeling of chemicals commonly known as GHS.  The actual documentation of GHS (i.e. the Purple Book) by UNECE can be found in the EBI Library.  The GHS seeks to standardize the way all countries in the world categorize, document, and label chemicals.  Since each country already has its own set of standards and regulations, it is up to each country to ‘harmonize’ their existing requirements with the GHS.

The GHS system covers all hazardous chemicals and can be applied to chemicals in the workplace, transport, consumer products, pesticides and pharmaceuticals. The target audiences for GHS include workers, transport workers, emergency responders and consumers.  The two major elements of GHS are:

1. Classification of hazardous chemicals (e.g. classifying pure chemicals and mixtures according to GHS criteria or rules)
2. Communication of the hazards and precautionary information using Safety Data Sheets (SDS) and product and carton labels

GHS and Labeling

When GHS is fully implemented by the local regulatory authorities (e.g. OSHA, DOT, FDA, etc.) it will require all product labels, including labels for shipping cartons and secondary packages as well as primary product labels to comply with new warning symbols, color codes, product identifiers, numbers, signal words, hazard statements, and precautionary statements. The three main required GHS label elements are:

• Symbols
• Signal Words
• Hazard Statements

Symbols

GHS requires a set of symbols to convey health, physical and environmental hazard information.  Each is assigned to a GHS hazard class and category. Pictograms include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors that are intended to convey specific information.  A hazard symbol featuring a white sprawling mass within a bust of a human is used for carcinogens, mutagens, reproductive toxicity, aspiration hazards, respiratory sensitizers and substances which have target organ toxicity. Harmful chemicals and irritants are marked with an exclamation point. Pictograms will have a black symbol on a white background with a red diamond frame.

GHS uses a second set of symbols for transport.  Pictograms will have the background, symbol and colors currently used in the UN Recommendations on the Transport of Dangerous Goods. Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.  A downloaded and zipped a set of examples of all the pictograms and downloadable files from the UN website in the EBS Library.

Signal Words

“Danger” or “Warning” will be used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.  Some lower level hazard categories do not use signal words. Only one signal word corresponding to the class of the most severe hazard should be used on a label.

Hazard Statements

Standard phrases assigned to a hazard class and category that describe the nature of the hazard.  An appropriate statement for each GHS hazard should be included on the label for products possessing more than one hazard.

Additional required label elements include:

• Precautionary Statements: Measures to minimize or prevent adverse effects. There are four types of precautionary statements covering: prevention, response in cases of accidental spillage or exposure, storage, and disposal.
• Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the MSDS. The GHS label for a substance should include the chemical identity of the substance. For mixtures, the label should include the chemical identities of all ingredients that contribute to acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear on the label.
• Supplier identification: The name, address and telephone number should be provided on the label.
• Supplemental information: Non-harmonized information on the container of a hazardous product that is not required or specified under the GHS. Supplemental information may be used to provide further detail that does not contradict or cast doubt on the validity of the standardized hazard information.

GHS Label Format and Placement

The GHS includes directions for application of the hazard communication elements on the label. In particular, it specifies for each hazard, and for each class within the hazard, what signal word, pictogram, and hazard statement should be used. The GHS hazard pictograms, signal words, and hazard statements should be located together on the label. The actual label format or layout is not specified in the GHS. Annex 7 of the Purple Book explains how the GHS pictograms are expected to be proportional to the size of the label text. Generally the GHS pictograms are smaller than the transport pictograms.  Health, physical and environmental hazard information labels typically go on the primary product packaging.  The transportation label typically goes on the case.

 Who is affected by GHS?

As a worldwide initiative, every country is expected to ‘harmonize’ their systems with the GHS standard at some point.  The status of each country can be found on the UNECE website.

The United States is not fully in compliance.  Regulatory authority for chemical labeling standards is splintered amount different groups (OSHA, DOT, EPA, and CPSC).  The bulk of the compliance is expected to come from an initiative by OSHA to merge the GHS standard with the existing HAZCOM standards already in use.  Proposed amendments to the OSHA Hazard Communication Standard regulations to bring them into GHS compliance were published on September 30, 2009.  The new rules were submitted to OMB November last year and acceptance is expected in early 2012.

What you need to do

Until the new rules are approved by the OMB (very soon), there is nothing US manufacturers need to do.  Enforcement will not start until the rules are approved.  However, this is a good time to prepare.  At EBI, we recommend all of our clients get familiar with the GHS requirements and review their labeling systems for compliance.  Once the rules approved, we will provide more guidance on next steps.  EBI clients under support and maintenance agreement will get personalized assistance with a compliance plan from our support team.

References:

UNECE information about GHS:

http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

Bringing together different US regulatory bodies in one system: http://blog.msdsonline.com/2011/04/can-osha-nfpa-hmis-the-hazcom-standard-and-ghs-all-play-nicely-together/

OSHA Hazardous Communication Information:

http://www.osha.gov/dsg/hazcom/index2.html

Mistake #1 – Creating One Label File for Each Product

The Problem:  The ‘one product per label file’ dilemma

As companies grow, especially ones that grow fast, they must prioritize.  Product labeling can be an afterthought in the rush to get products out the door.  Often, the process of creating a label for a new product is not really a process at all.  Someone simply takes the label file of a similar product, copies it, updates it, and saves it.

It makes sense.  By copying the last file, we assume the overall layout is the same.  Hopefully it stays within the original guidelines dictated by the customer or by internal company standards (often in Marketing or Quality Assurance).  The user makes many assumptions when doing it this way.  But, when your priority is to get the product out the door, this is often the way labeling gets done.

This practice can go on for years and we have seen clients accumulate hundreds and even thousands of label templates this way.  Although not as efficient as it could be, most clients don’t really consider this a problem until a global label change requires the update of ALL the labels.  Example of global changes can include:

• Change of physical address (if address is listed on the label)
• Government mandates (i.e. CRF 21 Part 11)
• A company merger or takeover
• Software upgrades
• Customer mandates

The Risk:   Business interruption, loss of man hours, and mistakes

Labor is usually one of the highest costs a company faces.  Downtime for individual or group results in additional and unnecessary labor costs.  Losses may become catastrophic when the downtime reaches across departments or the entire organization.

Individual Labor Costs

Completing one of the ‘global change events’ mentioned above usually means someone needs to open, update, verify, and save EVERY label file ONE BY ONE.   If the number of files reaches into the hundreds (and they often do), this will take MANY hours.  Regardless if this task is taken all at once or spread over days, weeks, and months, the cost is real and effects the company’s bottom line.

Downtime across the Entire Organization

Computer system failures, such as a hard drive crash, can start a costly Cascading Crises (see Mistake #5 – Poor Labeling System Maintenance) that can interrupt your business operations across the entire departments or the entire organization.  A Lean Manufacturing operation deploying Just in Time manufacturing processes can quickly idle as the IT Department hurriedly tries to restore and update old recovered files or recreate them from scratch.  The downtime is exacerbated when dealing with a large volume of label files.  Regardless of your ability to recover old files, the recovery is likely to take valuable time.

Errors in Rebuilding

As human beings, we make mistakes.  The stress and pressure of rebuilding the label files quickly and keeping up with other job responsibly increases the likelihood of making mistakes.  The repetition of updating hundreds of labels under these conditions makes mistakes inevitable.  Since we cannot predict when or where these mistakes occur we won’t find them until an alert operator spots them during production or downstream in the supply chain where the penalties can be costly.

The Solution:  Consolidate to one or a few templates and control the process

How Label File Consolidation Works

Instead of creating a new label file for each product, we recommend standardizing on one or a small handful of label templates that can be reused for different (but usually similar) products.  All the major brands of industrial labeling software have the ability to use variable or fixed fields in the label file.  Thus the client can create a ‘template label file’ where all the data fields common to each product (company name, logo, address, etc.) are saved as fixed fields.  Data fields that vary depending on the part number are saved as variable fields.

The printing process works like this…the user enters or scans a ‘key field’ (usually a part number) into the software.  The software connects to a database (often in an ERP or accounting system) and uses that key field (i.e. part number) to look up other data that belongs on the label.  Fields such as item description, case pack, weight, size, color, etc. are pulled from the database.  The labeling software instantly populates the variable data fields on the label with this information and then voila!  The label prints perfectly.

Adding New Products Gets Easier

Need to add a new product?  There is no need to create a new label.  All we need to do is add that new product information to the database.  We can be absolutely sure that all labels using that template will print the same every time.

How to you know which files should be consolidated to templates?  Look for labels with:

• The same physical dimensions (i.e. all 4” x 6” labels)
• Similar general rendering or layout of fields
• Use of the same data elements: logo, product description, etc.

Stopping the ‘One Label File for Each Product’ Problem from Reoccurring

To help enforce the use of just a few ‘approved’ templates, many labeling software companies offer ways to control access to the templates.  For networked environments, these templates can often be stored in a secured database (like SQL) that can be centralized, protected, and backed up.

At EBI, we can help clients setup these system and can help automate the consolidation process.

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Looks Can Be Deceiving

BACKTRACK version 7 is out! The GUI looks very similar to v6, but under the hood, there are some significant changes. Overall I like what I see but, as often with change, there may be some short term pain.

Below are the three most significant changes that I think most likely to affect our group.

New Report Writer

The old Advanced Report Writer was a nice feature in BACKTRACK. Most competitive applications don’t have such flexibility in reporting. But it was frustrating at times…it wasn’t always completely WYSIWYG and lining up and controlling the fields was painfully time consuming. I have not mastered the new Advanced Report Writer but I can already see the improvements with the work I have done.

One HUGE downside…for those upgrading, you will need to rewrite ALL your old reports. Yes…you read that correctly…ALL the reports need to be rewritten. For some that will be quite a task but I think most will find the sacrifice worth it in the long run. Think of it this way…you will be a master in the new Advanced Report Writer by the time you finish updating all your old reports!

For those under Support and Maintenance agreement with us, I could put together a quick training webinar. If you are interested, please respond to this blog so I can gauge the interest level.

More Efficient Use of SQL…FoxPro out!

When BACKTRACK starting supporting SQL in addition to FoxPro, many clients with large databases were disappointed to find the SQL preformed more SLOWLY than FoxPro. Since the application was rewritten from the ground up, BACKTRACK v7 appears to work much faster with SQL which is good news. For those who still like FoxPro, the news is not so good. FoxPro is no longer an option for us. TEKLYNX no longer allows FoxPro databases in v7. Since Microsoft will drop support for FoxPro in 2015, I guess the writing was on the wall.

For those still on FoxPro, the news is not all bad however. For most of us conversion from FoxPro to SQL should be easy. Just backup the FoxPro, install version 7, then restore back and presto! You’re back in business.

HOWEVER…a word of caution!!! We have experienced problems with some clients…especially the ones with the bigger databases, converting over from v6 to v7 recently. BE CAREFUL because if you upgrade on the same machine and find the restore fails, you may not be able to go back…especially if you are in an unsupported version of the software.

For those on Support and Maintenance with us, I highly recommend you send us a copy of your backup so we can test it in our test environment BEFORE you initiate the upgrade process. Also, let us know when you plan to do the upgrade so we can assist you.

Import/Export Choices Updated and Consolidated

From what I have seen, changes to the Export and Import features will not affect most clients EXCEPT those who exported to text files that DO NOT use the comma as a delimiter (e.g. ~, |, %, ^, *, :, ;, etc.)

TEKLYNX cleaned out most of the formats available for export (and added XML which is nice). I suspect many of these were not being used anyway (e.g. Excel 5.0…is ANYONE still using Excel v5???). However, the ability to insert your own delimiter is also gone. This can be a major inconvenience if you have integrated BACKTRACK with an application that is not setup to accept the CSV standard format.

For example, we have a client using TabQuik with BACKTRACK. The default delimiter is a tilde (~). Since version 7 of BACKTRASCK does not have the ability to send files in the default format (with the tilde) anymore to TabQuik we need to change the setting in TabQuick to work with BACKTRACK. Now this is not the end of world…TabQuik can change the default delimiter. But this is one more thing to deal with during the upgrade. I hope to see TEKLYNX bring this feature back but the other formats I don’t think will be missed.

No DOS PDT Support…and Where is the Simulator?

Many are surprised to know how many of those old proprietary DOS terminals are still out there. But think about it. These devices are rugged and they get the job done. Why not keep using them until they finally break? Well, for BACKTRACK users I don’t think that will be an option any more.

The release notes for v7 didn’t mention anything about dropping DOS PDT support nor was there anything said about the PDT simulator. But…both seem to have mysteriously disappeared!

For those who will miss the simulator, there is another option. Microsoft has a free Windows Mobile 6 SDK / Simulator. It takes a few minutes to setup but it works really well. Here is the download page:

http://www.microsoft.com/download/en/details.aspx?displaylang=en&id=9263

As you can see in figure 5, the Microsoft emulator is much more realistic than the old BACKTRACK simulator. If you are interested but find the setup confusing, just comment on this blog. If I get enough interest, I will write up a set of simple instructions specifically for BACKTRACK.

Conclusion

The rewrite of BACKTRACK in v7 has improved the application and I am glad TEKLYNX put in the time and effort to complete it. For those who will need to invest the time to rewrite reports or change delimiters with other applications…hang in there! The extra time and effort will be worth it.

Download BACKTRACK v7 Release Notes:

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What type of benefits?

- Reduced human errors – data comes straight from the ERP system, no human intervention.
- More secure the labeling system – reduced risk of system failure, better process control
- Synchronization of production and ERP systems – real time visibility to the production floor
- Traceability – manufacturing data (lot, date/time) stored for QA purposes

How does it work?

Step #1 – Scan and Get Data
Pallets flowing from one of six productions lines enter one of three pallet wrapper machines. Just before each pallet enters the pallet wrapper, Accusort Axiom™ scanners search on the side and top of the pallet for a UPC barcode. The scanners output the results via Ethernet to the EBI Integration Tool. This tool executes SQL commands written by EBI to find the correct record in the production table and send this data to SENTINEL Data Exchange.

Step #2 – Wrap and Print

SENTINEL Data Exchange executes a print job through CODESOFT that increments a counter for both a serial number and pallet number. This allows the client to track the order and number of pallets produced at that facility and within each production run.
By the time the pallet exits the Lantech pallet wrapper, CODESOFT has sent the label data to the ID Technology 250 Applicator which waits for the pallet to pass in front of it. Once it does, the correct label, for the correct product, with the correct serial number and pallet number is applied to the side of the pallet.

Step #3 – Update MRP/ERP System

We are not done yet! TEKLYNX SENTINEL Data Exchange with CODESOFT updates the production table in Microsoft Dynamics Navision with the newly issued serial number and pallet number. Now Microsoft Dynamics Navision knows what was produced, when it was produced, where it was produced, and that serial numbers and lot number were assigned…a smart pallet labeling system indeed!

Sounds great but could YOU use such a system?

The system was relatively inexpensive to assemble and maintain and it scales very easily. Thus the more automated production lines you have, the greater the savings (i.e. it does not cost much more to support 5, 10, 20, or more production lines than it does to do one). So I would say the larger your operation, the greater the savings the more this makes sense.

It also works best if you use your MRP/ERP to schedule production. The system uses the schedule in your system figure out what to print and where to print it. If your production or label requirements are less complex, there may be other ways to work around it if you don’t keep the schedule in your system.

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Why this blog can help you

It is no accident that our first blog on the new website was created for BACKTRACK. For some time I have thought BACKTRACK, the nature of this unique software, and its loyal following could really use a blog.

As long term users know, working with BACKTRACK can be more of an art form than a science. When I work with clients to implement and/or upgrade their systems, I get the feeling there is a sense of relief that ‘I am not alone!’ During these engagements I love to share tips and tricks that I have learned over the past decade to help clients get more out of BACKTRACK.

Even after working with the software over all that time, I find I still learn from my clients as well as I see the creative ways THEY use it to keep track of things. Therefore, a forum where we can share ideas, frustration, and knowledge, seems like great idea and one that I hope can benefit us all.

What I need from you

Since each of us has a unique perspective and history with BACKTRACK, I need you to comment and contribute to the discussion. If you are like me, you have a long wish list of ‘things I wish TEKLYNX would change or fix’. Some updates like moving to SQL, improving the report designer, etc. seemed to take FOREVER! As you may know, the software has been bounced around to several different companies after the acquisition from Strandware so you may have wondered ‘where is this all headed’?

But…I do interact with the Product Manager and support team at TEKLYNX from time to time and they do solicit feedback from our organization. BACKTRACK now seems to have a stable home and with the release of version 7, it seems TEKLYNX is making a commitment to invest in BACKTRACK’s future. Truth be told, they don’t always act on my suggestions but they do listen and pass on comments and ideas to the development team and TEKLYNX does has shown a sincere interest in maintaining and improving BACKTRACK.

So please post your thoughts, frustrations, and ideas. Let me know what find most helpful. Would you like to see?

• ‘Tips and tricks’ I have gathered over time?
• Get updates from me on new features, releases, upgrades, etc. that may help you solve a problem or fix a software bug?
• Put questions out to the group to get feedback on how to solve real world problems with (or within) BACKTRACK?
• Voice your concern or frustration about changes made to BACKTRACK or the future direction?

Your feedback will determine the future of this blog.

What we will do

For our part, EBI will keep this blog going as long as we have customers using and benefiting from it. We will listen and respond to honest and constructive feedback and share ideas and techniques. In the end it is our hope this blog can be one more tool that we can use to help our clients be more productive and more efficient!

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Production shutdown, hard drive crashes, loss of man hours, lawsuits, government sanction, costly shipping errors, and customer fines or loss of the customer’s business altogether…these all sound scary but can your labeling system create these problems for you?  If your organization labels things, then most likely the answer is yes!

The problem often sneaks up on you.  The accumulation of labeling system setup errors may cause a slow drip of wasted tasks and activities in production wearing away at your company’s profitably.  You may not notice the loss of company resources with wasted label materials and unnecessary IT support calls.  On the other extreme, lack or good labeling system discipline, control, and maintenance can lead to catastrophic system failure.  These problems often appear to come from nowhere and bring the business to a halt.  In either case, the risk is hidden but real.

Most of these issues can be prevented.  Many of the ‘slow drip’ problems are easily solved.  Preparing for the catastrophic ones allow you to reduce the downtime from hours or days to just minutes.  In this guide we hope to help you understand the common issues and if they might affect you, assess the potential impact to your business, and explain what you can do about it.

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