Safety Data Sheet (SDS) Expiry and Risk of Compliance

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. We are currently waiting on information from Health Canada on moving towards GHS Version 7 but at this point in time, we have no further information for you.  So what do we do with our SDSs in the meanwhile?

Although federally the three-year expiry has been abolished, there are still requirements for updating your SDSs if you sell within Canada.  If new significant data is obtained, the SDS must be updated to include this new information. Information considered significant new data could include but is not limited to new carcinogen data.  Any change that impacts the classification of the product as a whole would be considered significant.

In addition to new significant data, some provinces are requesting that a new SDS be prepared every three years even though federally it is no longer a requirement. WorkSafe BC for example is requesting that an SDS continue to be updated every three years to ensure compliance. When an SDS is three years old, an employer must obtain an up-to-date SDS from the supplier.

According to a conversation I had with the Canadian Centre for Occupational Health and Safety, Saskatchewan, Yukon, The North West Territories, and Nunavut are also requiring updated SDSs every three years.

If you intend to sell to these provinces, be sure to keep your SDSs up-to-date.

What should you do in the meanwhile if my SDSs are ‘expiring’ for the above-mentioned provinces?

Contact Dell Tech Laboratories if you have any questions about your SDSs or compliance requirements. If your Canadian SDS is not within three years, it requires an update.

We are your experts in GHS classification and can help keep your SDS compliant within the three-year requirements.  For more information on SDS requirements in Canada, contact us!

Contact:
Dell Tech
Kirsten Alcock, B.Sc. (Hons) 
Manager, Product Safety Group
519-858-5074
kirsten@delltech.com

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