ATIEL, the technical association of the European lubricants industry, together with ATC, the technical committee of petroleum additive manufacturers in Europe, has developed new guidance to improve the quality and efficiency of HSE (health, safety and environment) information sharing across lubricants supply chains.
The guidance, developed through the two organisations HSE committees, includes best practice recommendations for the preparation of Safety Data Sheets (SDS) for components or additives supplied to lubricant formulators, and a standardised Component Information Form that makes it easier for suppliers to provide additional information that doesnt typically appear in a component SDS but which is important for formulators and end users.
The SDS best practice recommendations address phrases and data formats in sections of a component SDS that commonly create issues for formulators in developing a finished lubricant SDS for passing down the supply chain.
The guidance document highlights where additional detail is required (or would be helpful), explains why this information is needed and provides recommendations for how to incorporate the information into an SDS.
These areas contain information that gives formulators a complete picture of the respective hazards of individual components, which may vary from supplier to supplier or region to region, and hence have a different impact on the profile or classification of the final lubricant formulation, says Angie Woodcock, Senior Regulatory Chemist at Shell and a member of the joint HSE task force.
Having this information is critical for developing a detailed and comprehensive SDS for a finished lubricant. Without it, formulators frequently have to go back and ask suppliers for clarification or information, which is time-consuming and inefficient for everyone in the supply chain.
In the majority of cases, even where the information may be of a proprietary nature, it only takes some minor amendments to the SDS to give the formulator the input needed while maintaining confidentiality.
She adds that, as most SDS are software-generated, it is often the software that limits the ability of the SDS author to provide additional info other than by adding notes manually. It is hoped that the ATIEL/ATC guidance document will also help SDS-writing software companies to improve their programs to produce SDS that enable efficient conveyance of complete HSE information down the lubricant supply chain.
In addition to the SDS guidance, the joint HSE working group has also developed a standardised Component Information Form (CIF) that additive component or mixture suppliers can use to provide important information that may not normally form part of the SDS structure.
The data covered by the CIF is essential to enable formulators to develop detailed product composition data that complies with national product registration schemes, customs requirements and substance registration regulations such as REACH.
The CIF is a simple Excel template that suppliers can complete in order to provide formulators with information on the composition of components or mixtures, details of restricted substances, country specific data and relevant handling and storage issues, says Woodcock.
Capturing this information in a consistent and standardised format will help to ensure that finished lubricants supplied to customers have the correct classification and labelling and that all the HSE data needed to support the product in the market is available. The template allows additive suppliers to provide the same consistent information to all their customers.
Olaf Kral, chairman of ATIELs HSE Committee, adds: The development of the SDS guidance and CIF template is the result of several years effort and cooperation between ATIEL and ATC.
With regulatory requirements increasing exponentially in recent years, this has put great demands on expert HSE resources across the industry. These documents will not only help improve the quality of lubricants HSE information being transmitted down through the supply chain, providing everything needed for regulatory reporting requirements, but could also help to reduce the overall workload for all stakeholders.
Sharing this information in an agreed and standardised way brings greater transparency and efficiency to the process of regulatory compliance for additive suppliers and lubricant formulators and will also benefit our end users.
The latest versions of the SDS best practice guidelines and the CIF template are available from the HSE section of the ATIEL website and from the ATC website.
