Canadian Safety Data Sheet Requirements: Disclosure of Ingredients
By: Kirsten Alcock, Manager of Product Safety, email
One of the main areas my clients struggle with is what chemicals require disclosure in section 3 of a Safety Data Sheet (SDS) and how do we disclose them. Depending on what country you are selling to, there are indeed different requirements. Today I will be focusing on Canada. The requirements for section 3 on a Canadian Compliant SDS are listed out in Schedule 1 of the current Hazardous Products Regulations. For a Canadian SDS, you must have the chemical name/common name, CAS number, and concentration.
If you choose NOT to include the CAS or proper chemical name, you must apply for an HMIRA Trade Secret. For more information on HMIRA Trade Secret, see:
Today I want to focus on the concentration. Over the years, the information pertaining to how to write the concentration on an SDS has changed. In the older Controlled Products Regulations, there were a set of ranges that Health Canada permitted on an SDS. When GHS (WHMIS 2015) came into play, these ranges were revoked and exact percentages were required. Industry fought back and we again have ranges we are permitted to use within section 3. Please note however that they are NOT the same ranges we were provided in the past.
Below you will see information from the previous regulations (CPR) and those of the new regulations (HPR). They are similar at the lower range but as you increase the amount of that ingredient within your product, the ranges in which the chemical can be disclosed is very different from in the past. In the past the range 60-100 was acceptable. This is no longer the case. I continue to see this range used today on SDSs we receive from suppliers. Please ensure that you update your SDSs to meet the new range requirements as 60-100 is not considered an acceptable range for your SDS.
Controlled Products Regulations:
Hazardous Products Regulations:
If you would like further information on your safety data sheet requirements and/or are interested in updating your existing documents to be in compliance with the HPR, please contact us. We’d be happy to help you with the process.
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
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