In this installment of our series, we highlight the things you need to know about the new regulations for Safety Data Sheets and labels required under WHMIS 2015.
Safety Data Sheets – SDS
Under previous WHMIS 1988 legislation, every hazardous material was required to have a Material Safety Data Sheet (MSDS), in both French and English. This is still the case under WHMIS 2015, but these sheets are now called Safety Data Sheets (SDS) and require more information on a material.
For suppliers, the transitional period runs through June 1, 2018, as described in the following schedule:
|Suppliers must use a label and (M)SDS for each hazardous product that fully complies with either WHMIS 1988 or WHMIS 2015 requirements (but not a combination of the two).|
1 June 2017 through
|Manufacturers and importers are required to provide SDSs and labels in the new format required by WHMIS 2015 for all hazardous products sold and/or imported into Canada. (This deadline concludes the transition period for manufacturers and importers, but not for distributors.)|
|3||1 June 2018|
Transition to WHMIS 2015 is complete for all suppliers, including distributors.
How do the MSDS requirements of WHMIS 1988 differ from the SDSs requirements of WHMIS 2015?
Under WHMIS 1988, MSDSs on all hazardous materials were required under 9 main categories, or sections. The new format for SDSs under WHMIS 2015 are a coupling of the original MSDS requirements of WHMIS 1988 with the SDS guidelines set forth by GHS.
WHMIS 2015 SDSs require detailed information on all hazardous materials to be reported in a document comprised of the following 16 sections:
- Includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
- Hazard Identification
- Includes all GHS (and WHMIS) hazards regarding the chemical; required label elements.
- Composition/Information on Ingredients
- Includes information on chemical ingredients; trade secret claims.
- First-Aid Measures
- Includes important symptoms/ effects, acute, delayed; required treatment.
- Fire-Fighting Measures
- Lists suitable and unsuitable extinguishing techniques, equipment; chemical hazards from fire.
- Accidental Release Measures
- Lists emergency procedures; protective equipment; proper methods of containment and cleanup.
- Handling and Storage
- Lists precautions for safe handling and storage, including incompatibilities.
- Exposure Controls/Personal Protection
- Lists Canadian occupational exposure limits broken down by each Province (13 in total), appropriate engineering controls; personal protective equipment (PPE).
- Physical and Chemical Properties
- Lists the chemical’s characteristics.
- Stability and Reactivity
- Lists chemical stability and possibility of hazardous reactions.
- Toxicological Information
- Includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
- Ecological Information
- Not mandatory – Includes ecotoxicity data, Persistence and degradability, Bioaccumulative potential, Mobility in soil and other adverse effects.
- Disposal Considerations
- Not mandatory – Information on safe handling for disposal and methods of disposal, including any contaminated packaging.
- Transport Information
- Not mandatory – Transport by land (TDG), Sea (IMDG/IMO) and air (IATA).
- Regulatory Information
- Not mandatory – Safety, health and environmental regulations specific to the product
- Other Information
- Includes the date of preparation or last revision.
*It is important to note that including information on categories 12 through 15 is not required in Canada. However, the headings must still be present on every SDS, even if the information is left off the sheet.
While the purpose of both MSDSs and SDSs is the same, requirements for MSDSs allowed for much greater flexibility and appear to be less standardized. In contrast, SDSs must follow a more tightly prescribed format that defines the exact headings and subheadings to be included, the order in which they must appear, the verbiage required for reporting risks and potential hazards of a substance, and the wording of precautionary statements describing how to properly protect oneself in the event of an exposure.
Under WHMIS 2015, all materials that could be considered hazardous must be labeled with a strict set of information, as was the law with WHMIS 1988.
Information required on labels under WHMIS 2015 has been largely unchanged from previous legislation — however, some things have been reworded and the format is slightly different.
All product labels under WHMIS 2015 must include the following information:
- Product identifier – the brand name, chemical name, common name, generic name or trade name of the hazardous product.
- Initial supplier identifier – the name, address and telephone number of either the Canadian manufacturer or the Canadian importer*.
- Pictogram(s) – hazard symbol within a red “square set on one of its points”.
- Signal word – a word used to alert the reader to a potential hazard and to indicate the severity of the hazard.
- Hazard statement(s) – standardized phrases, which describe the nature of the hazard posed by a hazardous product.
- Precautionary statement(s) – standardized phrases that describe measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product or resulting from improper handling or storage of a hazardous product.
- Supplemental label information – some supplemental label information is required based on the classification of the product. For example, the label for a mixture containing ingredients with unknown toxicity in amounts higher than or equal to 1% must include a statement indicating the percent of the ingredient or ingredients with unknown toxicity. Labels may also include supplementary information about precautionary actions, hazards not yet included in the GHS, physical state, or route of exposure. This information must not contradict or detract from the standardized information.
One of the most major changes to labels under WHMIS 2015 are the pictograms, which have been updated to feature the red square borders of GHS, replacing the symbols with black circles required by WHMIS 1988.
Further, WHMIS 2015 labels are not required to feature a black-hatched border – a requirement of WHMIS 1988.