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Canada’s GHS Implementation: Phase 3

By: Kirsten Alcock, Manager of Product Safety, email

On February 11, 2015, Health Canada published in the Canada Gazette, Part II the Hazardous Products Regulations (HPR), which modified the Workplace Hazardous Materials Information System (WHMIS) 1988 to incorporate the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for the workplace. This modified WHMIS is commonly referred to as WHMIS 2015. The Controlled Products Regulations (CPR) has been repealed and replaced with the HPR.

The first deadline for Canada GHS implementation for SDSs and labels was June 1, 2018 whereby all manufacturers and importers were required to be using the new WHMIS 2015 Hazard labels as well as the newly formatted SDS. Phase two passed on August 31st of this year. In this phase, distributors were required to get their SDS and labels into compliance to meet the new GHS requirements.

We are now in the final phase, Phase 3. In this phase, employers are required to have the documentation in-house updated to meet the new requirements. This phase ends November 30, 2018.  As of December 1, 2018, all SDSs and labels for Canada must be in the new format. There are no extensions in place.

There is some confusion regarding the use of US labels and SDSs in Canada. Although we are all part of North America, our regulations are quite different. Canada is using GHS Version 5 statements therefore any US product that is being imported and sold into Canada must have these version 5 statements included on their SDS and label. Currently the US is using Version 3.

Another big difference between the two countries is the use of Trade Secrets. In Canada, if you wish to mask the chemical name on your SDS, you are required to apply for a Trade Secret number. This is not the case in the US therefore any SDS coming across claiming Trade Secret for a chemical name without a government issued trade secret number is not compliant.  

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.


Dell Tech has provided professional, confidential consulting services to the chemical specialty industry in Canada, USA, Europe and Asia for the last 35 years.  Contact us today for more information.

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