The consultant who said “Just copy this”

(And how blind trust nearly derailed a product line) 

They thought they had found their guy. 

The consultant came highly recommended. A freelancer who had “done dozens of PCNs” and promised to make the process fast and painless. 

He sent a spreadsheet template, asked a few generic questions, and said: 

“No need to overthink this. Just copy the SDS data into the sheet. I’ll handle the rest.” 

That should’ve been the first red flag. 

But the client was under pressure. Launch dates were set. Labels were already being printed. So they went with it. 

They filled out the spreadsheet, sent it back, and waited. 

The consultant submitted five PCNs. The company pushed the products to market. 

And for a while, everything was fine. 

Until they updated their SDSs six months later. 

That’s when a sharp-eyed quality manager noticed something odd. 

One product had a UFI code that didn’t match the formulation it was now tied to. Another had an incorrect classification that didn’t align with the actual mixture. And one submission included a component they had never even used — it had been copied from a completely unrelated product line. 

When they confronted the consultant, his reply was chilling: 

“That’s just how I do it. It’s close enough.” 

Close enough? 

Not to the poison centres. Not to  the client’s legal team. 

They had to pause distribution because the PCNs made by the consultant were incorrect Notify partners. Resubmit multiple PCNs. And spend weeks reviewing everything the consultant had touched. 

All because someone said, “Just copy this.” 

The real lesson 

Not all help is helpful. 

There’s a big difference between doing something and doing it right. 

PCN compliance isn’t an area where “almost correct” is good enough. 

If someone suggests shortcuts that feel too simple, too fast, or too vague — they’re not making things easier. They’re making them riskier. 

And when you trust someone else with your submissions, you’re not outsourcing the responsibility. You're still on the hook when things go wrong. 

The name on the fine isn’t the consultant’s. It’s yours. 

What I recommend 

If you work with outside help, great. Just make sure you’re not working blind. 

Ask: 

• Are they tailoring submissions to your actual formulations? 

• Do they review SDS, classification, and labeling together?  

• Can they explain why they chose a specific classification or range?  

• Do they give you a submission report that makes sense — or just a checkbox? 
   

And if someone tells you to copy an SDS into a spreadsheet and call it a day, walk away. 

That’s not a consultant. That’s a shortcut wrapped in a liability. 

Final thought 

The sad part? 

This client didn’t need to fix their product. Just their process. 

They thought hiring someone meant they were safe. But hiring the wrong someone put them in more danger than doing it themselves. 

So yes, delegate. 

But never abdicate. 

If you want compliance done right — with eyes open, checks in place, and zero guesswork — that’s the kind of help I offer. 

Because “close enough” is never close enough when your entire product line’s on the line.