Effective Date: Revision Date:

G pbi/GORdon CORpORation An Employee-Owned Company SOS Request and Development Process Business Group(s) affected: Regulatory, Product Development, ...
5 downloads 0 Views 2MB Size
G

pbi/GORdon CORpORation

An Employee-Owned Company SOS Request and Development Process Business Group(s) affected: Regulatory, Product Development, Marketing, Operations Reference:

Effective Date: Revision Date: 8-24-16

INTRODUCTION: A Safety Data Sheet (SDS) is required for all finished goods and Manufacturing Use Products (MUP's) sold by PSI-Gordon. The Occupational Safety & Health Administration's (OSHA) Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As part of the standard an SDS must be created for products sold to outside parties, supplied for testing, and Manufacturing Use Products by PBlGordon Corporation. PURPOSE: The purpose of this process is to detail the request and development of SDS's for use in the Pest Management business unit. SCOPE: 1. GENERAL REQUIREMENTS: Regulatory, Marketing and Operations specifically Environmental Health and Safety (EHS) use the SDS Request and Development Process (SDS Process) to develop and maintain SDS's for all PSI-Gordon Pest Management Company Products. Additionally the process covers the EHS management of Wercs and WercSmart in support of Group 3 and 4 customers. Each step in the following work flow delivers specific results designed to move the SDS to the next step in the process. 2.

ENFORCEMENT: Non-compliance with this policy must be approved in writing by both the Vice President of Regulatory and EHS Manager.

3.

REVIEW: The policy will be reviewed and updated as needed by the applicable department(s); updated accordingly and will then be approved by management. Revisions will be dated.

1. PURPOSE The purpose of this document is to describe the processes involved in SDS development, maintenance, and distribution.

2. SCOPE Workflow 1: Safety Data Sheet (SOS) Request - New Finished Goods 1.1 SOS Request Form 1.2 SOS Development 1.3 Wercs and WercSmart Population Workflow 2: Safety Data Sheet (SOS) - Manufacturing Use Products (MUP) 2.1 SOS Request Form 2.2 SOS Development 2.3 Wercs and WercSmart Population Workflow 3: Safety Data Sheet (SOS) Request - Name Change Only (Formula is identical to existing product.) 3.1 SOS Request Form 3.2 SOS Development 3.3 Wercs and WercSmart Population Workflow 4: Safety Data Sheet (SOS) Request - Sub-registered Products 1.1 SOS Request Form 1.2 SOS Development 1.3 Wercs and WercSmart Population Workflow 5: Safety Data Sheet (SOS) Request - R&D Samples 4.1 SOS Request Form 4.2 SOS Development 4.3 Wercs and WercSmart Population

3. WORKFLOWS Workflow 1: Safety Data Sheet (SOS) Request - New Finished Goods 1.1

SOS Request Form Trigger: A new registration, product has progressed to Section 5.0 in the Research and Business Development Process. An existing product, there are desired or required changes to the existing label. Reactivation of a shelved or dormant registration. Product Manager or Account Manager (Gr. 4) initiates the Safety Data Sheet (SOS) Request Form posted on the PSI-Gordon intranet and circulates it to all effected departments. Product Manager or Account Manager copies Project Management on the e-mail when SOS information is requested. All information is returned to Project Management for assembly and confirmation of receipt prior to sending to EHS for SOS development. Product Manager or Account Manager completes Section I then forwards the SOS Request Form to Operations/Quality Manager for completion of Section II; Regulatory to complete Section Ill and Production Chemist or Director of Laboratory Services to complete Section IV. Once all departments have completed their section, Project Management supplies EHS with the request form and data and notifies EHS to begin SOS development.

Result: Clear understanding and communication of information needed to complete SOS in a timely manner.

Next Step: 1.2 SOS Development 1.2 SOS Development Trigger: EHS receipt of completed SOS Form from Project Management. Project Manager submits completed SOS Form to EHS for development of SOS. EHS Support Specialist creates the initial draft of the SOS. It then goes to the EHS manager for the first draft review. Any necessary changes are made a and second review of the SOS is completed . The EHS support specialist then creates an internal batch routing sheet and packet for review. The packet includes any labels for the product, the draft SOS, the old MSDS if applicable, and routing sheet. The packet then goes through the review loop. Customer Service & Logistics Manager reviews the transportation section, the Document Control Specialist reviews the regulatory sections for registered products, the Fertilizer & State Regulatory Specialist reviews for non-registered products, Chief Production Chemist for product chemistry, and back to EHS for final review and sign off. If any additional changes are requested as part of the review they are made by the EHS support specialist and a final review is conducted by the EHS manager. Once approved, EHS holds the completed SOS until final Container Label is complete. When available, container label is compared to SOS to ensure correct product name. Once product name has been confirmed on the SOS, EHS publishes the SOS. EHS will advise Project Management of SOS publication via email with the approved SOS attached. Upon receiving the email from EHS, Project Management will save a copy of the SOS to the Shared drive/New Product Development folder (saved in the appropriate product folder). Project Management will send the Product Manager or Account Manager, Regulatory Specialist and Manager Registrations Specialist an email advising SOS is published and where it is posted on the shared drive.

Result: Completed SOS. Next Step: 1.3 SOS published to WERCs web viewer for all master/mother SDSs and aliases. 1.3 Wercs Publication Trigger: Completed SOS. EHS publishes the SOS in the required format specified in the initial SOS request form. Formats and languages may vary depending on the initial request. Alias requests are also published at this time

as well. EHS populates Wercs and WercSmart (as needed) with the completed, approved SOS. The need for population into WercSmart is determined by Account Manager or Tractor Supply Account Manager.

Result: SOS for product is now available through the internet SOS search function site. The SOS is also sent to the customer when a new order is placed through the IFS system . Changes to SDSs also prompt the system to send a new revised copy to the customer, when a new order is placed .

Workflow 2: Safety Data Sheet (SDS) Request - Manufacturing Use Product (MUP) 2.1

SDS Request Form Trigger: For a new Manufacturing Use Product (MUP), a liquid product or Weed & Feed based on the MUP has progressed to Section 5.0 in the Research and Business Development Process. Keep in mind, PB I-Gordon does not generate an SOS for end-use weed and feed products produced by our customers. Each customer is required to generate SDSs for their end use weed and feed products. Product Manager or Account Manager (Gr. 4) initiates the Safety Data Sheet (SOS) Request Form posted on the PB I-Gordon intranet and circulates it to all effected departments. Product Manager or Account Manager copies Project Management on the e-mail when SOS information is requested. All requests are managed for follow through by the Product Manager or Account Manager and information is returned to Project Management for assembly and confirmation of receipt prior to sending to EHS for SOS development. Product Manager or Account Manager completes Section I then forwards the SOS Request Form to Operations/Quality Manager for completion of Section II; Regulatory to complete Section Ill and Production Chemist or Director of Laboratory Services to complete Section IV. Once all departments have completed their section, Project Management supplies EHS with the request form and data and notifies EHS to begin SOS development. Result: Clear understanding and communication of information needed to complete SOS in a timely manner. Next Step: 2.2 SOS Development

2.2 SDS Development Trigger: EHS receipt of completed SOS Form from Project Management. Project Manager submits completed SOS Form to EHS for development of SOS. EHS Support Specialist creates the initial draft of the SOS. It then goes to the EHS manager for the first draft review. Any necessary changes are made a and second review of the SOS is completed. The EHS support specialist then creates an internal batch routing sheet and packet for review. The packet includes any labels for the product, the draft SOS, the old MSDS if applicable, and routing sheet. The packet then goes through the review loop. Customer Service & Logistics Manager reviews the transportation section , the Document Control Specialist reviews the regulatory sections for registered products, the Fertilizer & State Regulatory Specialist reviews for non-registered products, Chief Production Chemist for product chemistry, and back to EHS for final review and sign off. If any additional changes are requested as part of the review they are made by the EHS support specialist and a final review is conducted by the EHS manager. Once approved, EHS publishes the SOS. EHS will advise Project Management of SOS publication via email with the approved SOS attached. Upon receiving the email from EHS , Project Management will save a copy of the SOS to the Shared drive/New Product Development folder (saved in the appropriate product folder). Project Management will send the Product Manager or Account Manager, Regulatory Specialist and Manager Registrations Specialist an email advising SOS is published and where it is posted on the shared drive.

Result: Completed SOS.

Next Step: 2.3 SOS published in WERCs web viewer for all master/mother SDSs and aliases.

2.3 Wercs Publication Trigger: Completed SOS. EHS publishes the SOS in the required format specified in the initial SOS request form. Formats and languages may vary depending on the initial request. Alias requests are also published at this time as well. EHS populates Wercs and WercSmart (as needed) with the completed, approved SOS. The need for population into WercSmart is determined by Account Manager or Tractor Supply Account Manager.

Result: SOS for product is now available through the internet SOS search function site. The SOS is also sent to the customer when a new order is placed through the IFS system. Changes to SDSs also prompt the system to send a new revised copy to the customer, when a new order is placed.

Workflow 3: SOS Request - Name Change Only (Formula is identical to existing product.) 3.1

SOS Request Form Trigger: Decision to rename an existing product. Product Manager or Account Manager (Gr. 4) completes the asterisked items in Section 1 of the Safety Data Sheet (SOS) Request Form posted on the PSI-Gordon intranet and forwards it to Project Management. Project Management confirms all necessary information is included on the request form then forwards the SOS Request Form to EHS for SOS development.

Result: Clear understanding and communication of information needed to complete SOS in a timely manner. Next Step: 3.2 SOS Development 3.2 SOS Development Trigger: EHS receipt of completed SOS Form from Project Management. Project Manager submits completed SOS Form to EHS for development of SOS. EHS creates SOS and tracks through internal review process. A name change will result in a new internal product number. The EHS Support Specialist creates an internal WERCs copy of the old SOS to make the new SOS with the name change. Since only the name has changed and the product number EHS reviews that those two things are correct. The product does not go through the standard review loop and no packet is created. Once approved, EHS publishes the SOS. EHS will advise Project Management of SOS publication via email with the approved SOS attached. Upon receiving the email from EHS, Project Management will save a copy of the SOS to the Shared drive/New Product Development folder (saved in the appropriate product folder). Project Management will send the Product Manager or Account Manager, Regulatory Specialist and Manager Registrations Specialist an email advising SOS is published and where it is posted on the shared drive.

Result: Completed SOS. Next Step: 3.3 SOS posted in Wercs systems for customer use. 3.3 Wercs and WercSmart Population Trigger: Completed SOS.

,



I

I

EHS publishes the SOS in the required format specified in the initial SOS request form. Formats and languages may vary depending on the initial request. Alias requests are also published at this time as well. EHS populates Wercs and WercSmart (as needed) with the completed, approved SDS. The need for population into WercSmart is determined by Account Manager or Tractor Supply Account Manager.

Result: SOS for product is available to the Product Manager and customers as needed.

Workflow 4: Safety Data Sheet (SOS) Request - Sub-registered Products 4.1

SOS Request Form Trigger: For a new sub-registration, product has progressed to Section 5.0 in the Research and Business Development Process. For an existing sub-registered product, there are desired or required changes to the existing label. Product Manager or Account Manager (Gr. 4) initiates the Safety Data Sheet (SOS) Request Form posted on the PB I-Gordon intranet and circulates it to all effected departments. Product Manager or Account Manager copies Project Management on the e-mail when SOS information is requested . All information is returned to Project Management for assembly and confirmation of receipt prior to sending to EHS for SOS development. Product Manager or Account Manager completes Section I then forwards the SOS Request Form to Operations/Quality Manager for completion of Section II ; Regulatory to complete Section Ill and Production Chemist or Director of Laboratory Services to complete Section IV. Once all departments have completed thei r section, Project Management supplies EHS with the request form and data and notifies EHS to begin SOS development.

Result: Clear understanding and communication of information needed to complete SOS in a timely manner.

Next Step: 4.2 SOS Development 4.2 SOS Development Trigger: EHS receipt of completed SOS Form from Project Management. Project Manager submits completed SOS Form to EHS for development of SOS. EHS Support Special ist creates the initial draft of the SDS. It then goes to the EH S manager for the first draft review. Once those changes have been made a second review of the SOS is completed. The EHS support specialist then creates an internal batch routing sheet and packet for review. The packet includes, any labels for the product, the draft SOS , the old MSDS if applicable, supplier SOS and routing sheet. The packet then goes through the review loop. Customer Service & Log istics Manager reviews the transportation section , the Document Control Specialist reviews the regulatory sections for registered products, the Fertilizer & State Regulatory Specialist reviews for nonregistered products, Chief Production Chemist for product chemistry, and back to EHS fo r final review and sign off. If any additional changes are requested as part of the review they are made by the EHS support specialist and a final review is conducted by the EH S manager. Once approved EHS holds the completed SOS until final Container Label is complete. When available, container label is compared to SOS to ensure correct product name. Once product name has been confirmed on th e SOS, EHS publishes the SOS. EHS will advise Project Management of SOS publication via email with the approved SOS attached. Upon receiv ing the email from EHS, Project Management will save a copy of the SOS to the Shared drive/New Product Development folder (saved in the appropriate product folder). Project Management will send the Product Manager or Account Manager, Regulatory Specialist and Manager Registrations Specialist an email advising SOS is published and where it is posted on the shared drive.

Result: Completed SOS.

I

'

J

\o

Next Step: 4.3 SOS published to WERCs web viewer for all master/mother SDSs and aliases. 4.3 Wercs Publication Trigger: Completed SOS. EHS publishes the SOS in the required format specified in the in itial SOS request form. Formats and languages may vary depending on the initial request. Alias requests are also published at this time as well. EHS populates Wercs and WercSmart (as needed) with the completed , approved SOS. The need for population into WercSmart is determined by Account Manager or Tractor Supply Account Manager.

Result: SOS for product is now available through the internet SOS search function site. The SDS is also sent to the customer when a new order is placed through the IFS system. Changes to SDSs also prompt the system to send a new revised copy to the customer, when a new order is placed . Workflow 5: SOS Request - R&D Samples 5.1

SOS Request Form Trigger: For a new, unregistered formulation to be sent out for testing in university or cooperator trials. Director of Laboratory Services inputs active ingredient and inert informati on into Wercs or Director of Laboratory Services makes an SDS request via email to the EHS Support Specialist.

Result: Clear understanding and communication of information needed to complete SOS in a timely manner. Next Step: 5.2 SDS Development 5.2 SOS Development Trigger: EHS receipt of completed formulation information into Wercs or an email from Director of Laboratory Services requesting the creation of an SOS. In the event the Director of Laboratory services creates the SOS they inform the EHS Support Specialist when it is ready for draft review. When the draft review is ready, it is then printed and provided to the EHS manager for the first draft review. Once the fi rst review is complete the EHS Support Specialist then makes any necessary changes and creates a routing sheet and packet to be sent out. The EHS manager receives the packet and reviews the SDS again . The EHS manager then signs off on the SDS and sends it to the Director of Laboratory Services for final review, and back to the EHS Support Specialist for any necessary changes.

Result: Completed SDS. SOS created in a pdf document and the SDS is sent to the Director of Laboratory which is then sent out to the client/customer.