MSDS: (REACH) Use & Exposure scenarios, unstructured data.
In first place, there is a property in the specification database ‘Use and exposure scenario’ where the uses and exposure scenarios must be informed. The reason, they must appear in the MSDS.
If we’re lucky and we are using ‘Product and REACH Compliance’, this hard work is made by our customers and providers. We send them an interactive Adobe form, and we just have to wait their answer. But if we only have a huge collection of pdf files, also known as unstructure data, each one containing all the known exposure scenarios for the substance, and we are trying to be compliant.
The MSDS can be sent automatically (SD_CALL) and manually (MAN_CALL), this is the reason why I discard to send a report shipping order with the MSDS, other with the exposure scenarios, and later make a package with both, the user will forget to create the second report shipping order.
So, the chosen solution is the following:
- Convert the pdf file (with 30-50 pages) to doc or docx, (I use Adobe Acrobat Reades DC)
- Create a document (CV01N) in DMS, I have create mi own document type.
- Upload the doc file as an original workstation aplication ‘DOC’ or ‘WRD’ (I have choose ‘DOC’) and storage the file in a data carrier.
- Release the document in DMS.
- Create an instance of the property SAP_EHS_1027_001.
- Add in label ‘User-Def.Text/Docs’ the DMS document. The User-Def. Text type must allow to assign a document (For example EDS – Document for exposure scenario), the language must be set.
In the WWI report I need to insert the following symbols.
If the file with the exposure scenario is only avaliable in a language (for example in English)
The reason to convert the pdf file to word is that WWI only show the first page of inserted object (pdf, xls,…), but insert all the pages with the doc. This can be checked in the WWI server, file WWI.ini, or from transaction CGSADM in ‘Application Parameters’.
thanks for generating this new document.
Only some hints: Pay attention on the REACH "legal" part..
"If we're lucky and we are using 'Product and REACH Compliance', this hard work is made by our customers and providers. We send them an interactive Adobe form, and we just have to wait their answer." =>this statement is not 100% correct from legal point of view: it is not "only" that customer/ providers have to do the work: you have to do it as well; it is possible to have an "overlap" of uses etc. with the customers; but in many cases you have more / or other uses to cover as well
So the "uses" in SDS/MSDS must cover your own uses (if you have done a registration !) as well. So any "unstructered" option can be used in some rare cases (in my opinion) and only for a limit time (and your technical solution is quite "clever"
But there is a "but". If you distribute now "your" own MSDS/SDS: what about language? E.g in your one example you use only the "EN" part ....
E.g. it is not allowed to have a MSDS/SDS in e.g. english and the appendix in "german"; so the work to get any ! language dependent version is huge.
But in any case: very good new document. Thanks
PS: clearly: it is a "pain" point to maintain the "uses" in a strctured way. But lucikly: we have now an agree upon XML schemata to share "exposure" etc. data in EU and SAP provides an interface: so we have now new options to handle the topic using a better approach,