3.4 SDS/EHS Gate for Chemicals
Procuring chemicals is fundamentally different from procuring hardware. A wrong resistor stops the board; a wrong chemical stops the factory. The arrival of an unauthorized, flammable, or toxic substance creates immediate legal liability, fire risk, and potential health hazards for the workforce. Procurement acts as the primary firewall. If the documentation is not perfect, the Purchase Order is not issued.
The Compliance Baseline (Minimum Viable Data)
Before price is even discussed, the vendor must provide the "Safety Passport" for the material.
Safety Data Sheet (SDS) Availability
- Requirement: An SDS compliant with GHS (Globally Harmonized System) standards must be on file before the PO is cut.
- Currency: Document date must be < 3 years old.
- Language: Must be in the local language of the factory (e.g., English + Spanish for a Mexico facility).
Hazard Classification Check
- Logic: Identify the "Signal Word" (Danger / Warning) and Pictograms.
- Impact: If the chemical is "Explosive," "Acute Toxic," or "Oxidizer," verify with the EHS (Environment, Health & Safety) Manager if the site has the legal permit to store it.
Storage Compatibility
- The Trap: Buying a 55-gallon drum of flammable solvent when the site’s Flammable Storage Cabinet is full.
- Rule: Procurement must confirm Space & Class.
- Question: "Do we have capacity in the Yellow Cabinet (Flammables) or Blue Cabinet (Corrosives)?"
The "Blocker" Protocols
Use these hard stops to reject requests immediately.
If Vendor cannot provide a GHS-compliant SDS:
- Then STOP. Do not buy.
- Why: Without an SDS, Receiving cannot legally handle the package, and First Responders cannot treat exposure.
If Composition is "100% Proprietary / Trade Secret":
- Then Trigger EHS Escalation.
- Why: We cannot assess interactions or disposal costs if we don't know the base chemistry.
If Container Size > Handling Capability:
- Then Reject.
- Example: Do not buy a 200L drum if the production floor only has manual lift carts. Request 20L pails instead.
Labeling & Disposal: The Full Lifecycle
Procurement owns the "Cradle-to-Grave" cost. The purchase price is often dwarfed by the disposal price.
Incoming Labeling Standards
- Requirement: Every individual container must have a GHS label (Name, Pictogram, Signal Word).
- Constraint: "White label" or handwritten jars are Forbidden at the dock.
The Disposal Path
- Pre-Check: Before buying a new chemical, define how it leaves the building.
- Cost Calculation: Total Cost = Purchase Price + (Disposal Cost / Unit).
Example: Buying cheap leaded solder requires expensive hazardous waste hauling. Lead-free solder goes to standard metal recycling.
Procurement Intake Checklist
Embed this checklist into the Purchase Requisition workflow.
Check | Question | Responsible |
1. SDS Check | Is a GHS SDS attached (Date < 3 Yrs)? | Requestor |
2. Storage | Is there physical space in the correct HazMat cabinet? | Facilities / EHS |
3. PPE | Do we own the required PPE (e.g., Butyl gloves)? | EHS |
4. Transport | Can the vendor ship via compliant HazMat carrier? | Procurement |
5. Disposal | Is a hazardous waste stream defined for this? | EHS |
6. Shelf Life | Is the volume < 6 months of usage? (Prevent expiring) | Procurement |
Final Checklist
Control Point | Requirement | Critical Threshold |
SDS Gate | No SDS = No PO | 100% Enforcement |
Records | SDS stored in central digital repository | Accessible 24/7 |
Sign-off | EHS Approval for NEW chemicals | Mandatory |
Quantity | Cap purchases to Storage Limit | Strict Volume Limit |
Labeling | GHS Labels on all inbound units | Zero Tolerance |
Disposal | Waste Stream Identified | Pre-Purchase |