WHMIS 1988 Classifications and Controlled Products Regulations References – Why are we still seeing on SDSs?
By: Kirsten Alcock, Principal Product Safety Consultant, email
To this day, I still see Safety Data Sheets (SDSs) that were written within the past couple of years referring to WHMIS 1988 classifications and using their symbols. THIS IS NOT COMPLIANT. An SDS intended for Canada must reference the current regulations we follow. We are NOT following the older WHMIS 1988 regulations. We have been utilizing the Hazardous Products Regulations (HPR) for quite some time. The HPR advises using a different SDS template, different symbols, different classifications, etc.
If you are purchasing and using SDS authoring software with the intent to provide an SDS for Canada, please ensure that the database is brought up to date with our legislation.
When a client supplies me with their supplier SDSs, one of the sections of an SDS that I automatically jump to is Section 15: Regulatory Information. It is in this section that I look for information on Canada. When I jump here and see a reference to the Controlled Products Regulations such as a classification like D2A, D2B, etc., I am hesitant to trust the information throughout this document.
Canada is currently using GHS (Globally Harmonized System) Version 5 statements which ARE different from the previous statements we used under the CPR. It is imperative that the appropriate phrases are being used here. Canada is expecting to move to adopt Version 7 later this year (*NOTE: the exact date is still undetermined) but until then, please ensure that you do have appropriate phrases and labels for use within Canada. Please ensure that you are complying with WHMIS 2015.
The older WHMIS 1988 hazard symbols were found in Schedule II of the Controlled Products Regulations (CPR). These symbols were circular, black and white, and they were used for Class A through Class F. The label was enclosed within a demarcated hatched border. Within the symbol was a picture that was indicative of the classification.
If you see these below CPR symbols on your current labels or SDSs intended for use in Canada, please ensure that you update your SDS and labels immediately. These symbols were revoked when the GHS regulations came into effect in Canada. I find that many SDS authoring systems refer to these older regulations in section 15 and it’s very disappointing to see and I’m sure disappointing to your company to know that the database software package you are using is indicating that these are still in use within Canada.
Controlled Products Regulations:
When the new regulations came into effect in Canada in 2015, we moved over to a different set of symbol requirements. These are referred to as Symbols and Pictograms. Under the new Hazardous Products Regulations (HPR), they can be found in Schedule 3 of our current regulations. There are some consistencies between the two as far as some of the ‘picture’ requirements but you will now notice that they are no longer within a circle and there is the color component red to them (note biohazardous infectious materials stays within a circle). In these new regulations, there are different symbols available for us to use such as the health hazard.
If you have any questions regarding the current WHMIS symbol/pictogram SDS and label requirements, do not hesitate to contact us. We can help you convert your older Material Safety Data Sheets (MSDSs) into SDSs that use the appropriate symbol not only on your SDS but also on your labels.
If the database software you have purchased refers to these older regulations or you are contracting your SDSs to be prepared by a consultant that refers to these older regulations, you’ll need to contact your supplier and urge them to bring their software up to date to what has been in use for many years now within Canada.
Contact us for further information on how we can help you meet your label compliance for Canada.
Kirsten Alcock, B.Sc. (Hons)
Principal Product Safety Consultant
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.