Vendor SDS Compliance – What does this service entail?
By: Kirsten Alcock, Manager of Product Safety, email
Workplaces in Canada receive Safety Data Sheets (SDSs) for the hazardous products that they purchase and bring in for their workers to use. Many of these products are imported into Canada and have SDS formats that do not meet the requirements of our law. Is that SDS compliant for Canada? Does it include all of the mandated information that must be on a SDS here? Is it compliant with our current version of the GHS regulations? Did they provide one in Canadian English AND Canadian French?
Many companies import products internationally and receive SDSs that do not meet the requirements here. Unfortunately GHS is a misnomer and one SDS cannot be used worldwide. Different countries adopted different versions of the GHS and some countries have their own country requirements on top of that. Take for example Trade Secrets. A product SDS can claim Trade Secret in the US without registration to the federal government. In Canada, however, we are required BY LAW to register for a Trade Secret on a SDS when we are trying to keep the chemical identity or CAS confidential. When a SDS comes to Canada with Trade Secret listed and no HMIRA number associated with it, IT IS NOT COMPLIANT and this product should not be used in your workplace.
Canadian workplaces need to ensure that the SDSs that are being used in-house by their workforce are compliant and meet the requirements. If you are not familiar with the laws/regulations pertaining to SDSs, we can help you with our new service.
What does Vendor SDS Compliance entail?
We offer three levels of service depending on what you are looking for:
- Determination of vendor SDS compliance with Schedule 1 of the Hazardous Products Regulations (HPR)
- Determination of vendor product chemical classification in accordance with the Hazardous Products Act/Regulations (WHMIS 2015)
- Preparation and authoring Safety Data Sheets (SDS) to be compliant with GHS, Hazardous Products Act/Regulations (WHMIS 2015)
How will Dell Tech go about it?
- Determination of vendor SDS template compliance with Schedule 1 of the Hazardous Products Regulations (HPR)
This service is used to determine if the vendor SDS received by a Canadian company is compliant with the current GHS regulations. Dell Tech will look over the SDS template to confirm that all headings and subheadings set out in column 1 and column 2 of Schedule 1: Information Elements on Safety Data Sheet are met. If the SDS template is not in compliance, Dell Tech will report the findings in a spreadsheet and advise your regulatory team. This report can be amended to suit your needs. One of the main formats I use is EXCEL and I will go through each individual section to advise of compliance issues.
- Determination of vendor product chemical classification in accordance with the Hazardous Products Act/Regulations (WHMIS 2015)
Dell Tech will determine what appropriate GHS categories and subcategories are required based on the formulation within section 3 as well as the product specifications including but not limited to flash point, pH, toxicological testing properties (LC50, LD50), etc. If the classification is determined not to be in compliance, Dell Tech will report the findings in a spreadsheet and advise your regulatory team.
In addition to this, we will also advise if a chemical that is listed with CAS is not on the DSL (Domestic Substances List) for Canada. If you are importing a product with ingredients that are not on the DSL, you become responsible for tracking the amount coming in and doing the New Substance Notifications.
- Preparation and authoring of Safety Data Sheets (SDS) to be compliant with GHS, Hazardous Products Act/Regulations (WHMIS 2015)
If the vendor template and classification are determined not to be in compliance with the HPR, Dell Tech will work with you and your vendor to create a SDS in our Dell Tech format that meets the current WHMIS 2015 requirements. Dell Tech will work under a confidentiality agreement with your vendor to obtain the full, complete formulation. Dell Tech will create an SDS using their in-house authoring software. The SDS will meet the current WHMIS 2015 classification criteria. A SDS will be created in English and Canadian French. Mexican Spanish is available upon request. A complimentary GHS Label will also be created. Dell Tech does NOT charge extra for the GHS Label, unlike other vendors. This information is currently available within section 2 of your SDS we would create. We provide this to make it easier for your team to have it available to over-label a product that was not brought in properly.
There are many situations where a SDS that does not meet compliance for Canada is simply translated into French thinking this will meet the compliance needs here. This is simply not the case. The overall SDS must be in compliance with the Hazardous Products Regulations as well as meet our bilingual requirements.
Dell Tech has been in the business of creating SDSs for over 40 years. Our Product Safety Consultants are experts on Canadian SDS requirements and can quickly advise if an SDS you are using does not meet compliance here. Please contact us to help you ensure your company is providing your workers with proper SDSs. It’s the law.
Contact:
Dell Tech
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
519-858-5074
kirsten@delltech.com
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.
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