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June 5, 2018
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[CANADA] Lockout: How to comply with regulatory measures?
August 7, 2018
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Jean Bruneau

WHMIS 2015 – Are you ready for the 1st of December 2018?

On February 11, 2015, the Government of Canada published the Hazardous Products Regulations (HPR) under Part II of the Canada Gazette. This regulation and the subsequent modification of the Hazardous Products Act (HPA) have led to changes in the 1988 Workplace Hazardous Material Information System (WHMIS), by incorporating the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) used in Canada.

The new version of the WHMIS is called “WHMIS 2015”.

The transition to the WHMIS 2015 involved a transformation period divided into three stages, synchronized nationally across federal, provincial and territorial jurisdictions. The deadline set for employers by federal, provincial and territorial (FPT) agencies responsible for occupational safety and health (OSH) in the workplace is December 1, 2018.

The key elements of the system are: classification of hazards, communication of hazards through the cautionary labelling of containers, and the provision of safety data sheets (SDS), as well as awareness programs and training programs.

Canada aligns with the GHS

“GHS” refers to Globally Harmonized System of Classification and Labelling of Chemicals managed by the United Nations. The GHS covers all hazardous products and their mixtures.

Canada already has laws in place for consumer products, pest control products, cosmetics, instruments, food and drugs, explosives and hazardous residues. These products can thus meet their current labelling and training sheet requirements.

The GHS covers two key elements:

  • The communication of information on hazardous products is standardized by the use of safety data sheets (SDS) and standardized labels.
  • The second element is concerned with the global classification criteria for hazardous products.

The GHS has a modular approach that enables hazard identification systems to have a common harmonized base. The competent authorities of various countries are free to determine which modules are applicable to different parts of their system.

What impact does it have on Quebec?

In Quebec, the modified legislation has been in force since June 3, 2015 in order to align itself with the provisions defined by the government. The Regulation respecting information on controlled products (RICP) (c. S-2,1, r. 8) and the Regulation respecting information on hazardous products (RIHP) will coexist during the transition period ending on December 1, 2018, when RIHP will replace the RICP. The occupational health and safety law and some regulations have also been modified.

What impact does it have on employers?

An employer whose workers use hazardous products should:

  • Review the training and workers information program in accordance with the requirements of the RIHP;
  • Train and inform workers about the latest forms and labels;
  • Manage inventory products and obtain forms and labels from suppliers, or failing this, prepare them himself.

An employer who manufactures hazardous products should:

  • Classify hazardous products in accordance with the hazardous products regulation HPR;
  • Prepare correct labels be it suppliers’ labels if he sells products, or workplace labels if he manufactures products for his own use;
  • Prepare safety data sheets with 16 sections for hazardous products manufactured by him.

An employer who is a supplier should:

  • Obtain safety data sheets of hazardous products from the manufacturer and ensure that the labels and the safety data sheets comply with the HPR;
  • Supply the labeled products and RIHP compliant safety data sheets as required.

Label content

Six elements of information are required on the supplier’s label according to the hazardous products regulation (HPR). Section 3 of Appendix 3 of the GHS document (Fifth revised edition, 2013) of the United Nations Organization specifies the standardized information of label contents:

  1. Signal word: It is one word, either“Danger” or “Warning”, indicating the presence of a potential hazard and its severity. The word “Danger” is used for most serious hazards, for example, corrosive effects on the skin. The word “Warning” is used for less serious hazards such as skin irritation.
  2. Hazard statement: It is a sentence assigned to each category or subcategory of the class of danger describing the nature of the hazard presented by a hazardous product.
  3. Pictogram: Hazard pictograms recommended by the HPR, with some exceptions, consist of a danger symbol in black against a white background with a red border in the shape of a square set on one its points.
  4. Precautionary statements: Statements describing the recommended measures tominimize or prevent adverse effects resulting from exposure to hazardous materials during storage, handling or use.
  5. Product identifier: It is the brand name, chemical name, common name, trade name or generic name of the hazardous material. It should be identical to the one indicated on the material safety data sheet.
  6. Initial supplier identifier: It consists of the name, address and telephone number of the manufacturer or importer of the hazardous material operatingin Canada.

Distinctive features of hazardous materials’ labels in Canada: When a product has the WHMIS 2015 label, it should be accompanied by a WHMIS 2015 safety data sheet. The WHMIS 1988 material safety data sheet is no longer permissible in this case.

Language: In Canada, the information contained on the label should be in both the official languages. It could be a bilingual label or two separate labels, one in French and the other in English.

Infectious substances: The GHS does not include the classification and labelling of infectious substances. However, in order to safeguard workers in Canada, such substances are considered to be hazardous by the HPR.

Safety data sheet: Following the harmonization of the WHMIS with the globally harmonized system of classification and labelling of chemicals (GHS), material safety data sheets (MSDS) comprising nine information categories have been replaced by another document called the safety data sheet (SDS) with 16 sections. This sheet shall be globally harmonized since it will be in force in all the countries that adopt the GHS. Since the SDS is standardized, it will be easier to use it, as the information will always be available on the same section on the form.

According to the hazardous products regulation (HPR), the SDS should comprise the following 16 sections:

  1. Identification
  2. Hazard identification
  3. Composition/Information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/Personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal information
  14. Transport information
  15. Regulatory information
  16. Other information.

Training

The occupational health and safety law, the Regulation respecting information on controlled products (in force until December 1, 2018) and the Regulation respecting information on hazardous products (RIHP) (in force since June 3, 2015) are very precise with regard to training. The training and information program is addressed to people exposed to or susceptible to hazardous materials. The employer should ensure that the training and information program is customized for workers, and is suitable for the specific conditions of the workplace and to the nature of the hazardous materials present there. The content of the training and information program is defined in Article 30 of the RIHP.

Should the employer train and inform workers about the WHMIS 2015 even though they have already attended information sessions on the WHMIS 1988? Yes, since important changes have been made with regard to the regulatory information of labels, safety data sheets, training and information program.

Moreover, workers should always be trained and informed on risks of exposure or about measures to be taken in case of emergency, whenever a new hazardous material is introduced in the workplace, when the employer comes to know of new and important data, or when changes take place that impact working methods.

Workers should also be trained and informed on the WHMIS 1988 if the labelling of products used in the workplace is compliant with that system.

Have modifications to the workers training and information program been made in the new regulation? Yes, in virtue of the Regulation respecting information on hazardous products (RIHP), two elements have been added to the training and information program:

  1. The program should envisage the means which the employer must implement in order to ensure better comprehension and proficiency with regard to the knowledge acquired by the worker, as well as his capacity to correctly apply safety rules for protecting his health and physical integrity.
  2. Training with regard to where the safety data sheets are stored, the means to access them, the technology related to the format in which they are stored, and the means to transfer them to a paper format.

CONFORMiT can help you

Thanks to its technological solutions, CONFORMiT offers a wide range of products and services that will help you to manage hazardous materials. These powerful and analytical solutions will meet your needs and expectations.

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