Are European Safety Data Sheets Permitted for Use Within Canada
By: Kirsten Alcock, Manager of Product Safety, email
Many of my international clients would like one safety data sheet (SDS) created for the world. Unfortunately at this point in time, this is not permitted. As I’ve discussed in multiple blogs, you need to ensure that you are providing an SDS that meets the laws of the countries you are selling your products in.
The European SDS has very different requirements than those in Canada. When my clients ask, “Can I use my European SDS in Canada?” My answer is always that it depends.
Canada has some unique requirements for Safety Data Sheet (SDS) authoring. Any product that requires an SDS in Canada must comply with the Hazardous Products Regulations. European SDSs are very different from those in Canada, not only is the template different, but the statements for the Globally Harmonized System (GHS) may vary as well. Europe has some unique statement requirements that one will not see on a Canadian SDS.
Below is a list of things you need to answer and comply with before sending your SDS to Canada:
- SDS for use in Canada MUST follow Schedule 1 of the Hazardous Products Regulations.
- Canada is currently following GHS Version 5 statements. These statements must be used on the SDS and label to be compliant. You cannot use later versions of the GHS.
- Canada also has additional hazard classifications for Physical Hazards Not Otherwise Classified (PHNOCS), Hazards Not Otherwise Classified (HHNOC), combustible dusts, simple asphyxiants, pyrophoric gases, and biohazardous infectious materials.
- Canadian French Translation requirements. This is not the same as French in European countries and may cause confusion to our French-speaking individuals within Canada.
- Is your European SDS including Occupational Exposure Limits for our Canadian provinces.
- Does your transportation section include the Transportation of Dangerous Goods that we follow here in Canada? The TDG in Canada is not the same as the different modes throughout Europe.
- Does your Regulatory section include our inventory lists: Domestic Substance List (DSL) or Non-Domestic Substance List (NDSL)? One is required to know this BEFORE importation of your product.
If you are not sure if you can use your SDS here, please send us a copy of your SDS and we can provide a quick check for you and your team.
HOW DELL TECH CAN HELP:
- Create a Canadian compliant SDS and GHS Workplace Label in Canadian English/French.
- Help classify your product for transportation within our Canadian borders and include this within your SDS.
- Advise on chemical inventory requirements which includes indicating which chemicals are/are not listed on the DSL/NDSL before you import your product. If they are not listed, we can help with your New Substance Notification Requirements.
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
Dell Tech has provided professional, confidential consulting services to the chemical specialty
industry in Canada, the USA, Europe, and Asia for the last 40 years.
Contact us today for more information.