Anyone can put up their virtual sign and say, “I translate,” but companies in need of SDS translation services should make sure to find a reputable company or individual translator.
Deeds cautions companies against sending SDSs or labels to just any translator. Her advice especially applies to section 2 of an SDS, the portion that identifies the hazards of the chemical and the appropriate warning information. A non-technical translator would likely not be aware that many countries have official translations of SDS elements like signal words and hazard statements that are required for SDSs to be compliant. If they don’t carefully select a translator, companies could end up with a label that their customers complain about because their regulatory body won’t accept it.
“Your classification under the GHS drives specific labeling related to the hazard classification,” Deeds explains. “For the most part, as countries adopt the GHS into their own regulations, they decide on official translations of hazard phrases and precautionary statements that would appear on the label.”
These official translations are readily available online in many places, Deeds says, but the most surefire way to find them is to look on countries’ hazard communication websites.
The HazCom Resources Committee of the Society for Chemical Hazard Communication (SCHC), of which Deeds is a past president and Das is a current board member, has published a list of translation resources (
PDF
) intended to help individuals select a firm to meet their translation needs. According to Deeds, the translators on that list have been vetted by chemical companies that have used them for technical translations. Companies can go to the listed firms with confidence that they’re going to get accurate output, she says. SCHC is a professional society that promotes knowledge and awareness in all areas of chemical hazard communication.
Das notes that another way to help the vetting process is to determine whether translators are accredited. One organization that accredits translators is the American Translators Association (ATA). By becoming ATA-certified, translators can document their abilities objectively in specific language combinations. Another resource is the ProZ.com Certified PRO Network of professional translators who have been certified by a professional association or screened by professional peers.
QUALITY CHECK
Companies have several options for validating the quality of translated SDSs and labels. Some larger companies have experts on staff like Rompre who can review SDSs in several languages. Rompre speaks French, English, and Spanish, and reviews the company’s SDSs and labels for all of North America. He recognizes the official phrases for the U.S., Canada, and Mexico, and is familiar with the different translation issues to look for to ensure that words and expressions are used properly in each language. Even SDSs for France and Canada, which both use the French language, might differ; certain words that mean one thing in Canada might mean something else in France, Rompre notes. But if an SDS or label is headed for a country in Europe that’s not France, a team of regulators working on registering the product in that country will take over to help him with any translation issues.
Depending on the nature of the product—for example, if it’s a fairly innocuous water-based cleaner—some companies may just have their sales representatives review the translation, Deeds says. Rompre confirms this; occasionally salespeople at his company jump in to look at translations. Still other companies implement programs where, after they receive a translation, they send it to their technical staff in that particular country. The technical staff will read it over and make sure it’s communicating the information correctly.
It’s common for firms that employ human translators to run SDSs and labels through a process for quality assurance and control. For example, firms might use editors to check translators’ work. Other technical translators might partner with scientists who are native speakers in other countries and can proofread and answer questions that may arise during translation.
The Synergist
’s sources agree that translations and review are best left to technical language translators and hazard communication professionals.
“It’s easy to say, ‘I’ve got somebody in the office who is fluent in whatever language,’ but they may not really understand the content of the SDS to do a good job,” Deeds says, stressing the importance of correctly communicating information about hazards and precautionary measures, especially for extremely hazardous materials.
“We want to make sure that the words impart the correct meaning within the context of the language and the culture,” she says.
KEEPING UP WITH GHS
Industrial hygienists and EHS professionals have varying degrees of involvement with SDS and label translation and conversion within their companies. Deeds recommends that IHs and EHS professionals educate themselves about the ever-changing requirements and regulations for hazard communication worldwide.
“IHs who want to practice in this area from a U.S. base need to have resources and partnerships to help them provide this expertise to their customers,” she says.
SCHC is one organization that can help professionals understand the way the rules change around the world and offer guidance on navigating translation and related work for their customers, according to Deeds. In addition to its list of translation resources, SCHC has other hazard communication resource
materials and information
for the development of SDSs, labels, and related documents. The society meets twice per year to provide training and development opportunities for hazard communication professionals. Das and Rompre echo Deeds’ praise for SCHC. Both regularly attend SCHC meetings to keep abreast of changes in hazard communications regulations.
“I had most of my GHS training through SCHC, and I even took the CLP training for Europe,” says Rompre. “They provide a lot of toxicology training as well.”
Many other organizations around the world also hold conferences and provide education to help hazard communication professionals understand international compliance challenges.
To help track the implementation of GHS in countries around the world, the United Nations Economic Commission for Europe (UNECE) maintains a
web page
where it collects publicly available information from various sources. As this issue went to press, UNECE had compiled and summarized information about GHS implementation for 72 countries.
Perhaps the best hazard communication resource for SDSs and labels is the official text of the GHS itself, widely known as the “Purple Book.” The United Nations published the 7th revised edition of the Purple Book earlier this year. The electronic version can be viewed and downloaded from the UN
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KAY BECHTOLD
is assistant editor of The Synergist
. She can be reached at (703) 846-0737 or via email
.Approximately five years have passed since OSHA released its revised Hazard Communication Standard, aligning it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The phase-in period for the standard ended on June 1, 2016, the date by which employers were required to revise their written hazard communication program, internal labeling, and signage, and train workers on any new hazards resulting from the change in the classification of chemicals.
OSHA’s standard only requires safety data sheets (SDSs) and labels to be available in English, making language requirements straightforward for companies operating exclusively in the U.S. But the U.S. is a major exporter of chemical products, and companies seeking to sell internationally routinely need to provide customers with SDSs that are not only compliant with other countries’ regulations, but are translated into the official languages of products’ destinations.
“GLOBAL IN NAME ONLY”
GHS, an international approach to hazard communication, is intended to provide a standardized approach to label elements and SDSs. Countries across the globe continue to implement GHS, many by adopting its recommendations into existing regulations. This method of implementation means that although GHS proposes harmonized hazard communication elements for labels and SDSs, requirements still vary by country.
Many people think that GHS means they can create one SDS that will work anywhere in the world, explains Atanu K. Das, CHMM, SDSRP, president and project manager at MSDSWriter, LLC, in Illinois. But that’s not the case.
“I always tell them, ‘It’s global in name only,’” Das says. “Or I say it’s ‘Generally Harmonized System’—that’s what the ‘G’ stands for.”
Denese A. Deeds, CIH, FAIHA, SDSRP, is co-founder and director of chemical regulatory services at Industrial Health & Safety Consultants, Inc. in Connecticut. She has often had to explain that companies must label their products in the languages of each country where they intend to place the items on the market.
“There’s some idea that GHS made the entire world speak English and accept the OSHA HazCom Standard, and it just isn’t that way,” she says.
For example, the European Union alone is home to more than 20 official languages. The EU’s regulation on classification, labeling, and packaging of substances and mixtures—the CLP regulation—requires that labels be written in the official languages of the member states where the substances or mixtures are placed on the market.
The best-fit solution for creating SDSs and labels that are compliant in other countries depends on a company’s resources—chiefly time and money—and how many documents are needed. Some companies use software to create and translate SDSs, while others turn to human translators or translation firms. Still others find a balance by outsourcing some or all of their SDS management to a third party.
“It behooves you as the purchaser to vet your vendors and make sure you’re confident in what your output is, no matter where it’s coming from—software or human,” Das says.
THE SOFTWARE SIDE
In general, SDS authoring and translation software works by allowing users to construct the documents either by manually selecting phrases or allowing a computer to add phrases based on certain hazard information and chemical properties. Software can help users organize this information into the appropriate SDS format. Multi-language SDS authoring software tools often come with a certain number of languages or allow users to purchase languages as needed.
For companies with specialized needs, some software is flexible in allowing users to add necessary phrases in different languages to supplement a standard software package. In many cases, companies can send the phrases they need to a translator and import the translations once they come back. Some software includes access to chemical databases, which can cut down on the time users spend manually searching for hazard information on their products. Users may be able to translate and make changes to an SDS based on country-specific requirements more quickly using this type of software.
For companies that need many SDSs in a handful of languages or that need a few SDSs in many different languages, software can be a cost-effective solution, Deeds says. But the software can be expensive.
“Companies have to weigh the costs of the software and all of the necessary maintenance that comes with it,” Deeds says. “How many translated documents do you actually need? You have to have a need that exceeds the cost of producing them in this way.”
Employees must also be trained on how to use the software. If individuals trained in using the software leave the company, additional resources will be required to train new staff, Das says.
Ghislain Rompre, PhD, who is responsible for generating SDSs at Scotts Miracle-Gro Company in Ohio, uses software provided by a third-party company to help do his job. Rompre, the senior scientist for product safety at the company, agrees that good software is pricey—the expense can often be prohibitive for smaller companies, he says—but notes its many benefits. He often has to create SDSs for product samples produced at a plant in the U.K. that need to be shipped to France for testing. The SDSs and labels accompanying those samples must comply with the requirements for both countries, which means that they must include two languages: English and French. Rompre tells the system which country and language he needs, and the software does the rest. An added benefit, he says, is access to a large chemicals database, which the system can use to generate classifications for new raw materials.
Individuals who don’t have access to this type of database have to manually search databases such as the European Chemicals Agency’s (ECHA) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) database, which can take a while. They may also have to lean more heavily on their professional judgment to “make the call” about hazard information.
“Let’s say you have a raw material that 40 percent of research papers say is an eye irritant, but 50 percent say it’s not,” Rompre explains. “What do you do? Most issues like this are taken care of thanks to our software, so there’s good payback, although it’s expensive.”
While it’s a helpful resource, users can’t rely completely on software for a chemical classification, Rompre cautions. A qualified individual must make the final determination.
“I have to make final decisions regularly, overriding the software’s decision,” he says.
Companies should realize the importance of updating SDS software regularly to account for rapidly changing hazard communication requirements in countries worldwide. Das stresses that companies should avoid using old software or databases that might be out of date.
“You have to continually be up on that software,” he says. “If that’s not something your company’s able to handle, then it might make sense for you to go the human route.”
A HUMAN TOUCH
Translation is more than turning words into another language; in many cases, a literal translation may completely change the technical concepts a company is trying to communicate on an SDS or label. Both Das and Deeds agree that companies opting for a human touch should use translators with good technical skills. Anyone can put up their virtual sign and say, “I translate,” Das says, but companies in need of SDS translation services should make sure to find a reputable company or individual translator.
“Because you’re conveying hazards on a document, you’re on the line for how you use the colloquial or idioms in the language of communicating that hazard,” he explains. “Like anything else you put on an SDS, you as the manufacturer are going to be ultimately liable for it.”
Over the years, Deeds has received a lot of feedback from the translators she works with. Sometimes the terminology or concepts she’s trying to communicate are so technical that she has to go back and forth with translators to make sure they understand the critical hazard information they’re trying to convey. For this reason, companies should plan on approximately 10 to 15 working days to turn around a translation. Faster service is usually available for additional fees, so budget-conscious companies will want to build in two to three weeks when working with a translator.
Find Credentialed SDS and Label Authors
The SDS and Label Authoring Registry recognizes chemical hazard communication and environmental health professionals who specialize in writing SDSs and labels. The Registered Professional: SDS and Label Author (SDSRP) credential provides recognition for individuals who have the skills and knowledge to properly prepare or review SDSs and labels to meet GHS requirements.
Learn more and view a list of registered professionals on the Registry's
website
.Preparing SDSs, Labels for
Use Around the World
Harmonized System
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