WHMIS 1988 Symbols and Controlled Products Regulations References – Why are we still seeing these on labels and SDSs?
By: Kirsten Alcock, Manager of Product Safety, email
I am noticing more and more that Safety Data Sheets (SDSs) coming from other countries into Canada are still referencing our older regulations. In the past, the SDSs were required to be in compliance with the Controlled Products Regulations (CPR). These regulations are VERY different from the current regulations. We are currently following the Hazardous Products Regulations (HPR).
When a client supplies me with their supplier SDSs, one of the sections of a 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 know that I am hesitant to trust the information throughout this document.
To this day, I continue to see these older WHMIS symbols on documents and the SDS referencing that it is “in compliance with the CPR”. When you see this on a product SDS you and importing, STOP. Ask your international supplier for an SDS that is compliant with the Hazardous Products Regulations (HPR) and ensure that the SDS is using GHS Version 5 statements.
Canada is currently using GHS Version 5 statements which ARE different than the US, GHS Version 3 statements. It is imperative that the appropriate phrases are being used here. Canada is expecting to move to adopt Version 7 later this year (*NOTE: Date still up in the air) 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.
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 current WHMIS symbol/pictogram SDS and label requirements, do not hesitate to contact us. We can help you convert your older MSDSs into SDSs that use the appropriate symbol not only on your SDS but also on your labels. Contact us for further information on how we can help you meet your label compliance for the GHS (Globally Harmonized System).
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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