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INDEX

I. INTRODUCTION
                                Objectives of this Study
                                About the Authors
                                Background

        Employer Requirements
                                Take Inventory
                                Review Purchases
                                Obtain MSDSs
                                Train Employees
                                Develop Written Program
                                Label Containers

        Responsibility for MSDSs (Table)
        OSHA's Working Group On Hazardous Communication

                                Electronic Transmission
II. ANALYSIS OF INDUSTRY NEEDS
        Distributor Files
        Focus Survey
        On-site Interviews
III. DISTRIBUTOR MSDS NEEDS
        Central Source
        Access By Catalog Number and UPN
        Common Format
        Need Status on all Products

IV. MANUFACTURER NEEDS
        Must be Cost Effective
        Manufacturers will Support
        Must Interface with Existing Systems
        Manufacturers are not Aware of Requirements
        Must Reduce Distribution Costs
        Delivery Must be Documented
        Solution Must Add Value to Products
        Solution Must Address Internal and External Needs

V. CONCLUSIONS
        Today's Answer Today
        Cost to Industry
        Manufacturer's Impact on Users
        Manufacturers Handle Their MSDSs in Different Ways (Table)
        Manufacturers Cost to Process an MSDS

VI. RECOMMENDATIONS

 

 

Material Safety Data Sheets
Building an Industry Solution to
Economical Compliance


HIDA large.jpg (2674 bytes)
  
    HEALTH INDUSTRY
        DISTRIBUTORS
        ASSOCIATION

Report Prepared by
MSDS-SEARCH. COM, Inc.
for the Health Industry Distributors Association
August 1997

                                                                                                             

 

I. INTRODUCTION

A. Objectives of this Study      INDEX

What is the purpose of this report?
The Health Industry Distributors Association (HIDA) has been directed by its Member distributors to determine the feasibility of establishing a Material Safety Data Sheet (MSDS) database for medical/surgical products to assist in bringing efficiency and economy into compliance with federal MSDS regulations. In aggregate these Members distribute more than 300,000 different products manufactured by over 2,500 vendors and see great need for the establishment of a central source of MSDS records.

Industry information indicates that the individual HIDA Member sells and distributes, on average, five thousand of these 300,000 items. Each Member must understand which of these products requires an MSDS, and be able to maintain the records in a system that provides access on demand. The current hidden cost for each member to duplicate these functions is burdensome.

It is the objective of this report to document distributor needs; outline current manufacturer practices, needs, and challenges; and present recommended industry solutions.

B. About the Authors         INDEX
MSDS-SEARCH. COM, Inc. builds and maintains MSDS libraries for various clients. HIDA contracted with MSDS-SEARCH to determine the technical and economic feasibility of building a consolidated MSDS database system to serve as a utility for HIDA Members. MSDS-SEARCH has been involved in similar health care field efforts over the past four years and has investigated nearly 30 commercially available software packages and MSDS data delivery services.

MSDS-SEARCH has built data bases of the type being considered for acute care hospitals and organizations in other industries. The MSDS databases for MSDS-SEARCH acute care hospital clients include products purchased from HIDA Members. These records came from data entered into an electronic format on behalf of MSDS-SEARCH hospital clients or were obtained from HIDA Member distributors as part of this study. MSDS-SEARCH. COM, Inc. can be reached at 121 Shivel Dr., Hendersonville, TN 37075, or by calling 800-284-2785.

C. Background        INDEX
For manufacturers, distributors, employers, employees, and the organizations that represent them, chemical hazards are an important issue. The Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 is straightforward in its intent:

"The purpose of this section (1910.1200) is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets, and employee training." (29 CFR 1910.1200 (a)(l)).

OSHA implemented the HCS in 1983, requiring chemical manufacturers to provide information regarding the harmful side effects of their products. Over the years, the coverage and complexity of the HCS has expanded greatly. Today, the HCS covers all manufacturers, distributors, and employers whose business comes into contact with hazardous chemicals - an estimated audience of 35 million persons in 3.5 million establishments. The HCS is now OSHA's most cited standard.

The HCS, also called the "Right-to-know" law, is of particular importance to distributors and other employers. It represents an administrative burden due to the many chemicals found in a typical facility, and an ongoing expense associated with legal compliance. This comes at a time when businesses are under intense pressure to cut costs and reduce overhead.

The guiding principle of the HCS is the idea that employees have the "right to know" the hazards and identities of the chemicals they work with, and the protective measures that they can take to avoid any adverse effects. The HCS addresses the issues of evaluating and communicating hazards to workers, which includes the production and dissemination of material safety data sheets (MSDS). Of course manufacturers of chemical products produced information regarding the proper handling of these products prior to 1983. However, there were no standards requiring or regulating these communications prior to the HCS.

What started as a good idea - providing employees with information about the chemicals to which they may be exposed so that they can protect themselves - has, in its execution, created enormous difficulties for everyone involved.

In the health care industry, for example, experience shows that the average distributor will have 5,000 to 10,000 products from 200 to 300 manufacturers that may require an MSDS. In addition to the sheer volume of data involved, purchasing decisions and periodic updates of existing records by manufacturers produce a dynamic condition, which frustrates any effort to keep files up to date. To complicate matters further, suppliers provide their MSDSs in a different format, and the user has no way of knowing if the MSDS he is providing to his customer is current.

Although the medical products industry has been universally supportive of the goals of the HCS, concerns have been raised about the paperwork burden and effectiveness of MSDSs. For instance, HIDA believes that the current definition of a "hazardous chemical" is too broad. According to the HCS, material safety data sheets are required for any chemical that poses any "physical or health hazard." OSHA estimates that this definition of a "hazardous chemical" is broad enough to include 650,000 different chemical products.

In addition, the distribution process of MSDSs is cited as not optimal. The HCS requires any chemical manufacturer or importer to assess the hazards of the products that they handle. If the product poses a physical or health hazard, the manufacturer must provide their distributor an MS DS, which must be transmitted to any employer that uses this product. The HCS further states that the employer must, "Maintain any MSDSs that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible during each workshift.

OSHA recognizes that many manufacturers are producing MSDSs for products which pose no hazard to their employees. In fact, many of the data sheets that are produced actually state, "no MSDS required." In addition, it is common for manufacturers to produce MSDSs for every single shipment of a product, which are then transmitted by the distributor to employers who believe that they are required to maintain the paperwork.

In addition, OSHA recognizes that MSDSs have become longer and more complicated over the years. As MSDSs are used to convey an increasing amount of information, they have become criticized for being incomprehensible, and therefore of little use to the employees that they are designed to protect.

Specifically, under 29 CFR 1910.1200, employers are required to do the following:
Take inventory of all chemical products.
A survey of the facility should be performed and a list of all hazardous chemicals and their locations compiled. The inventory, in order to be effective, must be a thorough "on-hands-and-knees" search of the facility as well as a review of all purchasing records. When completed, this record of where chemicals are used and stored must be kept up to date.    INDEX

Review purchase requests. When new products are ordered that contain hazardous chemicals, the MSDSs should be added to the appropriate department files and employees should be trained.

Obtain MSDSs. The HCS requires all employers to obtain and maintain up-to-date MSDSs for hazardous chemicals and make them accessible to employees. Employers are under obligation to request an MSDS if they don't receive one at the time a hazardous chemical is first shipped. MSDSs which contain information regarding first aid, responses to emergency spills and other protective data, must be immediately available to an employee in the event of an emergency. Pertinent MSDSs should be accessible in each department.

Train employees. The HCS requires employers to inform and train all workers who may be exposed to chemicals in the workplace under "normal conditions of use or in a foreseeable emergency" (29 CFR 1910.1200 (b)(2)). Training must take place at the time of initial assignment or transfer, as well as when any new hazard is introduced into the workplace.

Develop a written program. Employers are required to draft a written program that details how they will implement a hazard communication program in the workplace. It must be available at each work site and contain a list of the chemicals found at the work site as well as a current copy of the appropriate MSDSs. Responsibility for implementing the program should be assigned, and the method for informing employees and outside contractors about the hazards of the chemicals associated with their work should be documented.

Label containers properly. The HCS requires employers to ensure that containers of hazardous chemicals have an appropriate hazard warning label. If other languages are common among employees, labeling must be done in those languages, as should the MSDSs.

In order for employers to meet the above requirements, the HCS requires that manufacturers provide an MSDS:

Similarly, distributors are required to provide an MSDS:

The HCS, by assigning responsibilities to the various parties, endeavors to provide a seamless flow of hazardous chemical information from the author (manufacturer) to the end user (employee).

Responsibility for Material Safety Data Sheets
Manufacturer Must Provide
MSDS upon initial order
MSDS any time a significant change is made
MSDS any time it is requested
All Employers Must Provide
MSDS on every product containing hazardous materials
MSDS from manufacturer
MSDS that is the most current document
MSDS that is manufacturer specific
MSDS that can be archived for 30 years
after last use of product           INDEX
Distributor Must Provide
MSDS that is readily available to employees
MSDS with first shipment of product
When any MSDS changes
MSDS any time it is requested

OSHA's Working Group on Hazardous Communication        INDEX
In 1995, criticism of OSHA as a whole prompted the Clinton Administration to issue a report entitled "The New OS HA: Reinventing Worker Safety and Health." The report contained a number of suggestions, including the establishment of a working group on hazardous communication and the "right to know." This working group, the National Advisory Committee on Occupational Safety and Health (NACOSH), has provided OSHA with recommendations to simplify MSDSs, reduce the amount of required paperwork, improve the effectiveness of worker training, and revise enforcement policies so that they focus on the most serious hazards.

NACOSH has developed a number of recommendations pertaining to MSDSs, including:

  • A uniform format should be encouraged - such as the American National Standard Institute's Z400.1 format.
  • There should be a way that non-technical people can distinguish MSDSs covering the chemicals that fall under the HCS from those that do not.
  • Maximum use of electronic access and transmission of MSDSs should be allowed, as long as other requirements (e.g., immediate access) are met.
  • OSHA should take action to correct misunderstandings and misinformation regarding the issuance of non-required MSDSs and electronic access.

OSHA is now reviewing the actions of this working group.

Electronic Transmission. OSHA's NACOSH working group specifically addressed the issue of electronically transmitted MSDSs, and the use of outside management firms to handle this information. The summary of the discussion on this issue states, '"There was strong support for optimizing the use of electronic access and transfer of MSDSs." On the issue of off-site management the group states "that such services be allowed as long as the employees have ready access to the MSDSs."

II. ANALYSIS OF INDUSTRY NEEDS        INDEX

A three-step process was used to gather the information contained in this report. Specifically they were the MSDS files from three large distributors; a focus survey of nine distributors and nine manufacturers; and on-site interviews with distributors and manufacturers at HIDA/96 in September, 1996.

A. Distributor Files         INDEX
MSDS files from three large, national distributors were collected and analyzed. Included in these files were various tabulations, spread sheet reports and correspondence. This material was analyzed to determine various statistics related to the identification and number of manufacturers supplying products to the three distributors. The data
summary clearly demonstrates the expected concentration of a high percentage of products from a few manufacturers to the distributors. Since the distributors in this phase of the study were national in scope, the cost benefit for a manufacturer to distribute his MSDSs electronically to over 100 locations operated by only three distributors is obvious. The savings to be achieved by expanding this network to the more than 2,000 distribution locations operated by all HIDA Member distributors is unmistakable.

Specific attention was paid to a prior effort by Distributor A to collect current MSDS records from their manufacturers. Four hundred twenty manufacturers were contacted with a request that they supply MSDSs on products purchased from the individual manufacturer. Manufacturers not responding to the initial request were contacted a second time.

Of the 420 manufacturers contacted, documented responses were received from only 150 (36%). These responses varied greatly; 69 (16%) responded with letters or notations on copies of the request letter indicating that no MSDS was needed for the products listed. Some manufacturers provided full copies of MSDSs on certain products and a statement that no MSDS was needed on the remainder. Only a few responded with MSDS documents and a letter listing product names and catalog numbers for which no MSDS was required.

As noted above, the response rate was low (150 of 420; 36%). Our experience indicates that such a response rate is to be expected unless a diligent effort is made to identify the specific individual at the manufacturing company who is responsible for answering such an inquiry. Then someone should contact that person directly by telephone, prior to making a written request. Since many manufacturer companies operate from multiple locations, divisions, etc., locating the proper person to contact is often a major effort in itself.

B. Focus Survey    INDEX
A HIDA Task Group of 9 distributors and 9 manufacturers were contacted over a period of three months and surveyed regarding their product lines, methods of distribution of both products and MSDS records, administrative organization responsible for addressing MSDS issues, and what recommendations they could make for development of a system to improve the existing MSDS processing methods. Significant findings from these focus surveys are bulleted below and formed the basis for the on-site interviews conducted at HIDA/96.

           Findings

  • Some manufacturers write MSDSs for every product they produce, even though the MSDS may not be required.
  • Distributors can represent 5,000 to 300,000 products from up to 2,400 manufacturers.
  • MSDSs are created in different formats.
  • MSDSs are provided on multiple media (hard copy, disk, CD, FAX, microfiche, etc.).
  • Manufacturers change MSDS information frequently enough to cause a 30% to 40% turnover of an MSDS library on an annual basis.
  • Changes in purchasing and stocking decisions by distributors also cause a significant amount of change to the individual distributorís library. Approximately 10% of all distributor's line items change each month.
  • Most manufacturers and distributors do not maintain a centralized library of MSDS records for multiple location operations.
  • Many manufacturers do not require that a common MSDS format be used in publishing MSDSs for distribution by various operating divisions.
  • Few manufacturers are capable of supplying MSDS files in electronic format, although some can supply text copies from word processing programs.
  • Most manufacturers do not recognize the importance to the distributor of having the product identification code (product number, catalog number, UPN, etc.) on the MSDS.

C. On-site Interviews        INDEX
Interviews were conducted during the H1DAI96 Trade Show & Education Forum, September 7-10, 1996, in Ft. Lauderdale, Florida. The distributors were of various sizes and represented all four markets - Physician/Alternate Care, Hospital Care, Long Term Care and Home Health Care.

From these efforts the consensus needs of HIDA Member distributors, and medical products manufacturers have been defined.

III. DISTRIBUTOR MSDS NEEDS        INDEX

In addition to complying with the MSDS regulations required of all employers, distributors have other obligations under the law. Specifically, distributors are required to provide a current MSDS with the first shipment to a customer of any product requiring an MSDS, and on the next shipment following any change in the MSDS.

While a few distributors have automated the process by scanning known MSDSs into an electronic file, most distributors maintain paper copies of product MSDSs received from manufacturers. Some distributors cross-reference a code to this product file in the computer system. When that code appears on the shipping document (indicating that this is the first shipment of this product to the customer), it is read by a person who then manually retrieves the MSDS from a file, makes a photocopy and includes it with the shipping document in the product package. Because a change in the MSDS requires that the new MSDS be sent with the next shipment to each customer receiving the product, all of the codes would need to be changed with each MSDS change. Consequently, some distributors have chosen to send the MSDS with every shipment of that product.

This additional paperwork burden is further complicated by the distributors' customer service function. Customers, particularly hospitals and other accredited healthcare facilities, periodically review all regulatory systems in their operation. During these reviews, MSDSs are often found to be missing and a request is forwarded to the distributor. The distributor handles that request as an important customer service inquiry. Except in those few cases where the distributor has invested in an electronic file, someone must physically search the product file for the MSDS(s) on the specific product(s) requested by the customer. If none is found (which is often the case), the distributor places a phone call to the manufacturer to request the MSDS. If the product requires an MSDS, one is faxed to the distributor, and then it is faxed by the distributor to the customer. If the product does not require an MSDS the distributor is so informed by the manufacturer and that information is passed on to the customer. Oftentimes, the customer will require that the "no MSDS required" information be provided in writing, entailing more phone calls and faxes. Since most of the hundreds of thousands of medical products do not require an MSDS, the vast majority of requests for MSDSs come back "no MSDS required."

To make this process work better, and more economically under the current law, distributors need a system that will replace the manual product MSDS filing system, and subsequent duplication of work and cost, by allowing them to electronically access all products from a single source. Specifically, distributors agree on the following needs:

Central Source. The industry needs accessibility to a central electronic database of MSDS information, on demand and on-site at the distributor's location, on all medical/surgical products. The ability to access an on-site library is essential if the distributor is going to automatically generate an MSDS to accompany the shipment of those products requiring MSDSs.     INDEX

Access by Manufacturer Catalog Number and UPN. All product information in a distributor's system is keyed to the manufacturer's catalog number. In order to provide efficient access to MSDS information, manufacturers need to include the catalog number, as a separate and standard field, on the MSDS. The Universal Product Number (UPN), which is the health industry standard bar code number assigned by the manufacturer, will also need to be included as a separate field. This number is expected to eventually replace the catalog number.         INDEX

Common Format. Distributors strongly prefer that all MSDSs be in a standard format and of a maximum length. The standard format provides for more efficient cross reference and data input, in addition to making the information easier to use when needed. A fixed or standard maximum length also helps limit storage requirements, facilitate data input, and, again, make the document easier to use when needed.     INDEX  

Need to Know MSDS Status on all Products. It is as important that distributors know which products do NOT require MSDSs as it is to have the MSDS on those products for which they are required. The ability to make inquiries on-site to address customer requests will save tremendous time for everyone: distributor, manufacturer and the customer. If no definitive information is available on a specific product, the distributor request it from the manufacturer, in order to serve the customer. On the other hand, distributors DO NOT want MSDSs generated on products that do not require an MSDS. Having information on a manufacturer's full line of products, with an indication of which do not require an MSDS, will also (when keyed to catalog number or UPN) expedite the
automated search which is necessary on every line item if an MSDS is to be included with the proper shipments.       
INDEX

IV. MANUFACTURER NEEDS      INDEX 

The Focus survey and on-site interviews with manufacturers produced the following consensus needs:

An Industry Solution must be cost effective to implement. In order for manufacturers to support a centralized system, implementation and use will have to be cost effective. Currently, manufacturers are faced with multiple requests from software companies to put their MSDSs in a specific template so that the software company can then make the manufacturer's MSDSs available to the purchasers of the software. There are two major flaws with this approach. One, the manufacturer must provide the data in large numbers of different templates, one for each software company, which significantly increases the costs. And two, there is no central clearing house where all MSDS records can be audited to insure that current information is maintained.         INDEX

Manufacturers will support an industry database if they know their customers want it and will use it.  On numerous occasions manufacturers contacted during this project have indicated that they will do whatever their customers and distributors want. At the same time, they have little interest in providing documents in an unlimited number of formats due to the cost factors involved. Clearly, users of MSDSs must speak with one voice and adopt a single template for the transmission of MSDS data.       INDEX

An industry database must interface with existing systems. Manufacturers need to have the national data base interface with current software systems. It is unreasonable to expect a company to abandon a large investment in off-the-shelf or in-house developed software in order to be able to connect with a centralized database. In response, the national database communication system must be designed to interface directly with the manufacturer's system so that data can be transferred in the appropriate EDI format.       INDEX

Manufacturers are not uniformly aware of the requirements and economies. A recent exchange with a health industry manufacturer illustrates one area for savings. In this case, the raw materials in the products were the same, but the products were packaged differently and appropriately given different product numbers. The manufacturer then wrote an MSDS on each product number even though many of the products contained identical materials and could be included on the same MSDS. When asked why the company did not place multiple product numbers on a single MSDS, in order to reduce the total number of documents, the response was, "I don't know, we'll look into it". Two weeks later, after a five minute meeting with the company data communications people and a half hour reprogramming job, the response was, 'You know, no one had ever asked that question before. We just assumed that we had to have a separate MSDS for each product. Do you have any idea how much money that will save us?"        INDEX

A national database must reduce MSDS distribution costs. Economy of scale achieves the greatest leverage during the distribution of MSDS documents to users. Once a central healthcare products MSDS database is in place, when a manufacturer makes a change to an MSDS, it can be directly communicated to those 2,000 plus HIDA distributor operating locations that distribute that manufacturers products.        INDEX

The delivery of manufacturers' MSDSs must be documented. Because a national database can track the distribution of documents to all users, the manufacturer can receive management reports documenting that his MSDSs were received at a specific location, on a specific date and time.

The Solution must add value to a manufacturer's products. By providing MSDS documents in a standard EDI format, manufacturers can add significant value to their products. Customers have been struggling with the massive paperwork and data overload created by a combination of hard copy, faxes, CD-ROM, and other format MSDSs. It is easy to assume that the problem can be solved by manufacturers putting their MSDSs on the Internet. And in fact, if only 1, or 10, or possibly 100 MSDSs are needed, this is a slow but workable solution. If, on the other hand, you maintain a library of 35,000, or 100,000, or in our case 250,000 products, searching through 2,000 manufacturer's web sites becomes more of a chore. Unfortunately the question, "Which of my 250,000 files has changed?" still remains unanswered. By placing MSDSs in a single database that is continuously updated, manufacturers can provide their customers with MSDS documents that are inexpensive, uniform, usable and current. In addition, other product related information (latex content, national fire codes, tracking required, etc.) can be added to the data base if desired. Clearly this will represent a significant value added to a manufacturer's products.         INDEX

The solution should address internal and external needs. One very large Fortune 100 company recently told us, "We have solved the MSDS problem by making all of our documents available to our customers." When we asked how they deal with their own suppliers the response was, "It's a complete mess. We spend hundreds of thousands of dollars every year trying to scan MSDSs into our system, and it's not working." This manufacturer, like so many others, has overlooked the fact that another name for ''manufacturer'' is "customer". Manufacturers also need a single source of MSDS documents that they know are current and from their suppliers. By helping to solve the problem for their customers, manufacturers initiate the process of solving the problem for themselves.        INDEX

V. CONCLUSIONS        INDEX

Because no effort has been made to address the MSDS distribution situation from the point of origin to the point of use, and seek an efficient and cost effective solution, all participants (manufacturers, distributors and customers) are required to:

  • Collect their own MSDSs by whatever means possible.
  • Build their own MSDS libraries.
  • Buy or write their own software for any automation effort.
  • Administer their individual system and try to keep the records current.
  • Duplicate functions being performed by every other distributor, manufacturer and customer.
  • Duplicate resources and dollars.

The nearly universal response from all surveyed parties is that they are quickly overwhelmed when they attempt to build, let alone maintain, a manual MSDS tracking system. Automation of the MSDS effort is the only way to effectively handle so much information. But building an automated system is prohibitively expensive because of the high cost associated with data entry. A review of literature provided by commercial data entry services shows that the average charge for a full text MSDS document is approximately $30 per MSDS, plus the cost of obtaining the MSDS from the manufacturer. If a distributor had 10,000 products purchased from 200 manufacturers, the data entry expense ($300,000) would make automation a costly undertaking. Because full automation is prohibitively expensive, partial automation has been adopted in the form of scanning MSDSs into a data base and then building a partial index so that the required document can be retrieved.

All parties surveyed and interviewed readily agreed that a coordinated effort could lead to an increase in efficiency and savings for everyone.

A significant component of developing an effective MSDS network will involve the education of all manufacturers on the importance of keeping the number of "MSDS product files" as low as possible while covering the total number of catalog products available. This is because, as an industry utility, the service would be priced on a per usage basis. In building a data base administrative control of the information is achieved by assigning each MSDS document a unique file number. Retrieval of that file can then be made by a query on a field that contains multiple pieces of information including separate fields for the catalog number and the UPN. The computer will search the entire field for a pre-designated string of numbers or characters regardless of the amount of data in that particular field. If a manufacturer has several products which contain the same basic ingredients, publishing a single MSDS to cover all those products will reduce the number of documents to be included in the database. An economy of scale is attained with no sacrifice in the ability of the computerized system to search and recover the information on any of the products included.

A second major cost control factor relates to the frequency with which changes are made to individual MSDS records. Each time a change is made by the manufacturer it triggers an "update" to files being maintained in individual userís libraries. Every update will create a transaction charge to each library which contains that record.

Today's Answer, Today. The technology to distribute and manage MSDS information to meet HIDA Members requirements is available today. In order to implement the solution, a degree of order and discipline will have to be accepted by manufacturers, distributors and customers dedicated to addressing a common problem. Each of these interested parties will have to understand, and be willing to help solve, the issues related to their partners concerns. The thread that will tie these partners together will, to a degree, be dictated by the technological limitations of electronic communications.     INDEX  

In order to meet the needs of having a central MSDS source available to serve the needs of HIDA Members in a timely and cost effective manner, the information must be part of a relational data base, with the structure of the data entered being very regimented and clearly defined. Software writers desiring to participate in the data entry and/or retrieval market must accept the data base structure presented and incorporate it into their programs. Ideally, this database structure would allow the retrieval of any included file by searches including: file number, name of manufacturer, product name, synonyms, and manufacturer assigned product codes (product numbers, catalog numbers, part numbers, etc.). The computer is capable of conducting such a search in a very rapid fashion, but the search will not be successful unless the data has been placed in a location the computer has been asked to search.

Cost to the Industry. The current procedure of individual manufacturers, distributors and customers building their own automated MSDS management systems is prohibitively expensive, to the point that few are willing to make the attempt. Data entry software must be purchased by the user, with several packages to choose from, all priced in the three to four thousand dollar range. And entering an MSDS is a complicated learning experience, especially if the manufacturer is still using the eight part OSHA format and the data is being entered into the more popular American National Standards Institute (ANSI) sixteen part format.        INDEX

The speed at which the data entry person enters an MSDS is dictated by their understanding of what information is to be entered in which section rather than how many words per minute they can type. Commercial data entry services currently charge from $22 to $30 per MSDS processed. Again, this is prohibitively expensive to most product purchasers. The more logical method is to have the data entry made in a predetermined format by the manufacturer and transferred to the user 5 system electronically. An estimated processing cost of $15 per MSDS record has been used as a reasonable expense for such an identification and transfer. (The media transfer expenses are not included in this estimate and will depend upon the media chosen and the number or records to be processed per transaction.)

Most manufactures are not specifically aware of the processing cost implications of having an MSDS for each product or catalog number. One major manufacturer, who is well aware of such considerations and has done an excellent job of grouping their products by ingredient category for MSDS purposes, was able to include a total of 350 catalog numbers in only 33 MSDS files. At an estimated cost of $15 per file, the average cost per catalog number is $.47.

The Way a Manufacturer Writes his MSDSs Impacts Users. The way a manufacturer writes an MSDS has a major impact on the cost of maintaining and using the data. Currently, manufacturers have little understanding of the difficulties they unknowingly cause for their customers for the simple reason that they have not been told. And even if they are aware of the problem, it has not been economically feasible to provide a solution for only one user. The following example, taken from three HIDA suppliers, provides a graphic illustration of how an arbitrary decision on the part of a manufacturer can have a major impact on his customers:            INDEX    

Three Medical Products Manufacturers Handle their MSDSs in Different Ways:
Manufacturer A
Supplies 365 products on 365 MSDSs.
(Does not put multiple product numbers on MSDSs.)

$5,475
$15/Record or $15/Product
Manufacturer B
Supplies 350 products on 33 MSDSs.
(Does put multiple product numbers on MSDSs.)

 
$495
$15/Record or $1.41/Product

Manufacturer C
Supplies 10,000 products.
(Needs to state that no MSDS is necessary.
Could put all on 68 MSDSs.)        INDEX

$1,020
$15/Record or $.10/Product

From the above examples it is apparent that, based on how they write their MSDSs, manufacturers can have a major impact on their customers bottom line.

Manufacturer's Cost to Process an MSDS. Based on information from manufacturers, ranging in size from Fortune 500 companies to small family firms, it is clear that few, if any, actually know their own costs to distribute an MSDS. The reason for this is simple, the costs associated with MSDSs are not budgeted line items, and are therefore considered part of the general overhead of the company. The best data available to date comes from a Fortune 500 company and a government agency that did the work to establish costs of $50 and $35 per document, respectively. In both cases, a scanning system was the method employed to process the MSDSs.         INDEX

Another way to estimate costs is to look at the number of MSDSs processed. One medium sized medical manufacturer confided that he received in excess of 14,000 requests per month for his MSDSs. If we use this number, and assume that it takes five minutes for his staff to take a phone call, retrieve the MSDS and mail the document to his customer. A very conservative estimate of his costs would be:

            Phone charge on 800 line for request                         $.25
            Employee @ $8/hr for 5 minutes                                 $.67
            Paper supplies                                                                  $.05
            Postage                                                                              $.32
                                                                  Total per MSDS      $1.29

This manufacturer is spending more (probably a good bit more) than $18,000 per month to send out MSDSs, and this expense is being passed through to his customers in the form of higher product costs.

VI. RECOMMENDATIONS         INDEX

To address the needs HIDA, along with other nationwide industry organizations, must assume a leadership role in coordinating an effort between product manufacturers, distributors and customers to build an MSDS database which can be integrated into a network that will serve all their needs. Rather than believe if you don't do it, someone else will, accept the fact that if you don't do it, it will not get done.

Distributors must evaluate these recommendations, and after determining that they represent a solution to their problem, lend their support to building the shared database. This support should be demonstrated by a willingness to subscribe to and pay the fees associated with establishing and maintaining their local library, as well as actively urging their suppliers to participate.

Manufacturers must recognize the needs of their distributors and customers and agree that an industry-wide, shared MSDS database, addresses those needs. Their subscription as a provider of information will help fund the development of the database and make the records available for distribution that qualify as being "from the manufacturer".

        Specifically, HIDA recommends the following:

  • Make all information, MSDS and "MSDS not required", available to an industry designated database.
  • Adopt an MSDS standard format. The American National Standards Institute (ANSI) format is preferred.
  • Provide MSDS only on products that require MSDS.
  • Include catalog number(s) and universal product number(s) (UPNs) in a separate field on the MSDS.
  • Include all products with identical materials on the same MSDS.

Finally, customers must be educated on the efficiency and cost effectiveness of addressing their MSDS management requirements in this manner. Their promotion of the database to their suppliers will ensure that a library of current MSDS records is available when needed for the products they use. This addresses the need for the employer to have MSDSs available for review by employees that are "from the manufacturer" and "current."      

 

Health Industry Distributors Association
66 Canal Center Plaza, Suite 520
Alexandria, VA 22314-1591
Phone: (703) 549-4432
Fax: (703) 549-6495 
www.hida.org 

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