Most life sciences manufacturers that run into trouble
during an inspection already have the programs that pharmaceutical EHS
compliance calls for. There is a hazard communication plan, a waste contingency
plan and a corrective action procedure.
The finding tends to land somewhere else: in the step where
a record should have changed and didn't, because the work passed from one team
to another and nobody owned the handoff.
An EHS gap in pharmaceuticals is the distance between what a
site's procedures require and what its records can show on the day someone
asks. The four gaps below turn up again and again in OSHA citation data, EPA
settlements and FDA observations, and each one starts as an ordinary workflow
problem.
1. Safety data sheets for in-house APIs and
intermediates
Hazard Communication was the second most cited OSHA standard
in fiscal year 2026, with 1,961 violations recorded between October 1, 2025 and
August 31, 2026, according to preliminary figures released with the National
Safety Council in September 2026. Most of those citations go to ordinary
employers with missing labels or thin training records.
Drug manufacturers carry an extra duty on top of that. Under
29 CFR 1910.1200(g)(1), a chemical manufacturer has to author a safety data
sheet (SDS) for each hazardous chemical it produces, which is usually done by
SDS
creation software
.
This EHS gap in pharmaceutical manufacturing comes from a
split in ownership between the data and the document. Toxicology and
occupational exposure band data for a new compound sit with development, while
the SDS sits with EHS or regulatory affairs.
When a new study changes the hazard picture, the SDS often
stays as it was, even though the standard gives the preparer three months to
add significant new hazard information once they become aware of it.
OSHA's 2024 update to the standard, with the four-month
extension announced in January 2026, set these compliance dates:
Who must comply
Substances
Mixtures
Manufacturers, importers and distributors (SDSs and
labels)
May 19, 2026
November 19, 2027
Employers (workplace labels, written program, training)
November 20, 2026
May 19, 2028
The substance deadline for manufacturers has already passed.
Any in-house compound still on an SDS written to the old format is out of date
under the rule. Some manufacturers now run SDS Authoring in-house, generating
the document from the same composition and hazard data the process team
maintains, so the two records can't drift apart.
2. Hazardous waste records that lag behind the
process
EPA's June 9, 2026 settlement with Nitto Denko Avecia shows
how waste gaps build up at a working drug manufacturing site. The company
agreed to pay $858,889 to resolve federal RCRA and Massachusetts hazardous
waste violations at two facilities in Milford, Massachusetts. EPA's list of
problems covered five areas:
-
Hazardous waste air emissions.
-
Design and installation of hazardous waste tank systems.
-
Equipment inspections.
-
Labeling of waste and storage areas.
-
Contingency planning.
None of these is exotic. The corrective measures the company
put in place, including a leak detection program, daily tank inspections, and
updated emergency response plans, are routine tasks for any site that generates
hazardous waste.
There is a structural reason these tasks slip. Waste streams
change every time a process is scaled up, a solvent is swapped, or a new
product goes into a suite. The waste determination, the tank inspection log,
and the contingency plan rarely sit in the same change request as the process
update, so they fall behind by one revision, then two.
3. Corrective actions closed without an
effectiveness check
Corrective action is where EHS and quality systems look most
alike, and it is where EHS programs tend to be weaker. ISO 45001, the
occupational health and safety standard many manufacturers certify to, requires
an organization to review the effectiveness of any corrective action it takes.
Also, it requires keeping documented information on the results, including
whether the action worked.
Many EHS teams track the action and close it when the task
is done. The guard goes on, the procedure is revised, the training is delivered.
Nobody comes back 60 or 90 days later to confirm the original hazard is gone.
FDA observations show how regulators treat the same pattern
on the quality side. Citations under 21 CFR 211.192, the production record
review rule that requires investigation of unexplained discrepancies, rose
171% from 2023 to 2024 in Form 483 observations
issued to sterile drug manufacturers, according to an analysis published by
Pharmaceutical Online.
The EHS version of that finding is a repeat incident at a
workstation that already has a closed corrective action against it. The record
shows the investigation stopped at a symptom.
The fix is mostly about where the follow-up lives.
EHS CAPA Management Software
can hold the
effectiveness check as a dated, assigned task, so the action can't be marked
closed until someone confirms the fix held. A spreadsheet can do the same in
principle, though the follow-up column is usually the one left blank.
4. Process changes that skip EHS review
Scale-up, technology transfer and new equipment introduce
more new hazards in a shorter time than anything else a drug manufacturing site
does. ISO 45001 clause 8.1.3 requires a process for implementing and
controlling planned temporary and permanent changes that affect health and
safety performance.
Most GMP change control systems already route changes to
quality, regulatory, and validation reviewers. EHS is often an optional
reviewer, or gets copied at the end.
The consequences are visible in OSHA's fiscal 2026 list.
Lockout/Tagout ranked third with 1,863 violations and Respiratory Protection
sixth with 1,608. A process change touches both directly.
New equipment needs its own energy control procedure, and a
compound with a lower exposure band can move an operation from local exhaust
ventilation to respirator use, which brings fit testing and medical evaluation
with it.
Making EHS a required approver on change controls, with a
short checklist covering new chemicals, new energy sources, new waste streams,
and changed exposure levels, is a small addition to a process most sites
already run, and it closes one of the more common EHS gaps in pharmaceutical
manufacturing.
Closing the EHS gap in pharmaceuticals before
the next inspection
Each gap above sits between two teams: development and EHS
for safety data sheets, operations and EHS for waste, quality and EHS for
corrective actions and change control.
Companies that publish their EHS approach tend to describe
it as a single system. Alkermes, for example, describes a program built on an
enterprise-wide risk management
framework and
aligned with ISO 14001 and ISO 45001.
A practical place to start is one recent process change,
traced end to end. Check whether the SDS, the waste determination, the energy
control procedure, and any related corrective action all updated with it. Where
one didn't, the gap is already on record.