Canada’s GHS Implementation: Phase 1 Complete, Phase 2 now started – Are you compliant?
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 The Controlled Products Regulations (CPR) has been repealed.
The first deadline for Canada GHS implementation for SDSs and labels was June 1, 2018. All manufacturers and importers must now be using the new WHMIS 2015 Hazard labels in accordance with the HPR as well as the newly formatted SDS.
We are now into Phase 2 of the GHS implementation where distributors have until August 31, 2018 to get their SDS and labels into compliance. If you have not yet started the process, we urge you to act now as label changes can be a very lengthy process. Please ensure that you and your company have started this process
One thing to note is that although both the US and Canada are following the GHS, we are on different versions. Canada is using Version 5 statements of the GHS therefore any US product being imported and sold into Canada must have these version 5 statements included on their SDS and label.
Another difference between the US and Canada is that Canadian SDS’s must be provided in both English and Canadian French. One is permitted to send separate English and French documents or a combined English/French SDS but both must be submitted at the same time to all users within Canada. Simply translating a US SDS into French will not meet the compliance requirements for a product to be sold within the Canadian marketplace.
A big win for Canadian companies was the reintroduction of ranges. The originally adopted GHS regulations revoked the CPR ranges and manufacturers were required to submit Trade Secret applications to the HMIRA to continue their use. Recently an amendment was made by Health Canada and ranges are now permitted for use again. They are similar to the past but not exactly the same. There is also a trade secret statement required on the SDS to use said ranges.
If you would like more information about these aforementioned amendments or to change your existing document to use the newly adopted ranges rather than list the exact percentage, please contact Dell Tech Laboratories for further details on our SDS authoring process.