Full Compliance with the GHS (Globally Harmonized System)
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.’ All deadlines have passed for adoption and Canada is in full swing with the GHS. The final phase ended on November 30, 2018. Full compliance with the GHS should have been done in 2018 but still to this day I am seeing SDSs for Canada referencing the old Controlled Products Regulations rather than the Hazardous Products Regulations.
When you receive an SDS from a supplier, there are some key things you should be looking for when it comes to the Hazardous Products Regulations (HPR).
- SYMBOLS. If you are still seeing symbols within a circle rather than a diamond, the SDS is not compliant.
- IDL. If you are still seeing references to the Ingredient Disclosure List (IDL), the SDS is old. The IDL was repealed many years ago and should not be on a current SDS for Canada.
- CPR. If your SDS is referencing the Controlled Products Regulations (CPR) rather than the HPR (Hazardous Products Regulations), you need an update.
- WHMIS RANGES. If your SDS is still using the older ranges as permitted under the CPR, please ensure that these are brought up-to-date with the new ones within the HPR.
Full compliance with the GHS was expected back in 2018. If you see any of these on an SDS that you are accepting into your workplace OR if the SDS you are creating in-house for your clients has these issues, you need to obtain and/or update your SDS. Health Canada will consider an SDS without proper symbols or in compliance with the CPR as non-compliant and there could be implications due to these. Do not be caught being out of compliance!
If you have any questions regarding SDS requirements in Canada, do not hesitate to contact us. We can help you understand the current regulations under the Hazardous Products Regulations (HPR). We will provide an SDS and complimentary label that use the appropriate symbol and phrases. Contact us for further information on how we can help you meet your label compliance for the GHS (Globally Harmonized System).
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
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