WHMIS 1988 Symbols versus GHS Pictograms – Why are we still seeing these on labels and SDSs?
By: Kirsten Alcock, Manager of Product Safety, email
One of the most popular questions I have from my clients refers to compliance. IS MY SDS AND LABEL COMPLIANT FOR CANADA? This happens quite often with products that are being imported from other countries. One of the sections of a SDS that I automatically jump to is Section 15: Regulatory Information. I jump to this section as this is where one would find the old WHMIS 1988 symbols on an SDS and the reference to the older and now repealed Controlled Products Regulations (CPR). It is unfortunate but still 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.
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 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).
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
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