Canada’s GHS Implementation: Phase 3 Near Completion. Are you ready?
By: Kirsten Alcock, Manager of Product Safety, email
On February 11 2015, Health Canada published Part II of the Hazardous Products Regulations in the Canadian Gazette, which incorporated the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) with the Workplace Hazardous Materials Information System (WHMIS) 1988. This modified WHMIS is now referred to as WHMIS 2015 or ‘Canadian GHS.’
What deadlines have passed?
June 1, 2018: All manufacturers and importers are required to use the new WHMIS 2015 SDS format, classification system and hazard labels.
August 31 2018: Distributors must start using WHMIS 2015 compliant SDS and labels.
Where are we now?
We are now in the final phase, Phase 3, which ends November 30 2018. On December 1st, all Canadian employers must have their documentation updated to meet the new GHS requirements. No further extensions are permitted.
Can I use my US SDS and Label?
To answer this simply? No.
There is some confusion regarding the use of US labels and SDSs in Canada. Although we are all part of North America, the regulations are quite different. Canada is using GHS Version 5 statements; USA is using Version 3. Any US product imported and sold into Canada must have SDSs and labels in compliance with Version 5.
The US will eventually implement a newer GHS version, but there are no set dates at this point in time. GHS is an evolving regulation so expect changes to classifications and label requirements down the road, as the UN continues to publish new GHS revisions.
Another difference between the two countries is the use of Trade Secrets. Unlike the US, in order to mask a chemical name or CAS in Canada, one must apply for a Trade Secret number. Any SDS coming into Canada claiming trade secret without a government issued number is not compliant.
So, you’ve discovered your SDSs are not compliant. What now? Who do we contact?
Contact Dell Tech Laboratories. We are your experts in GHS classification and can help convert your existing SDS into a format that meets Canadian or the US requirements. We offer our SDSs in English, Canadian French and Spanish. Our SDSs include a complimentary GHS hazard label to include within your overall label.
If you would like more information about these aforementioned GHS amendments or to change your existing documents to use approved Trade Secrets numbers in Canada, please contact Dell Tech Laboratories for further details on our SDS authoring process.