WHMIS. How many symbols do I really need?
By: Kirsten Alcock, Manager of Product Safety, email
When we are working on a GHS WHMIS SDS for our clients, we provide an SDS that complies with the current HPR (Hazardous Products Regulations). Schedule 3 of the regulations contains the mandated symbols and pictograms that must be on a Canadian SDS to be compliant. Please follow this link to the appropriate symbols and ensure that you are using these for Canada.
What many clients may not realize, however, is that not all the symbols are necessarily required and I will discuss them in detail below. We provide the SDS with the appropriate amount but there are some additional exemptions that one may not be aware of. Under the HPR, there is a section that describes the precedence as there was in the previous Controlled Products Regulations (CPR). There is the ability to remove additional symbols. Let’s go into this in further detail.
SKULL AND CROSSBONES SYMBOL: When there is a requirement to provide the skull and crossbones symbol, the requirement to provide the exclamation mark to indicate ACUTE TOXICITY does not apply. Please note that the exclamation point can be used for multiple classifications. If you need the exclamation point for a classification other than acute toxicity, then you still require both.
CORROSION SYMBOL: When there is a requirement to provide the corrosion symbol, any requirement to provide the exclamation symbol to indicate SKIN OR EYE irritation does not apply. Again, as with the above example, if you need the exclamation point for a classification other than skin or eye irritation, then you still need both.
HEALTH HAZARD SYMBOL: When there is the requirement to provide the health hazard symbol to indicate respiratory sensitization, any requirement to provide the exclamation symbol to indicate skin sensitization, skin/eye irritation does not apply. As indicated above, should you need the exclamation point for a classification other than skin sensitization, eye/skin irritant, you will still require both.
Please ensure that you read these and fully understand when you can remove a symbol. These are the ONLY EXEMPTIONS that exist in Canada for the removal of a symbol.
If you have any questions regarding WHMIS symbol/pictogram requirements, do not hesitate to contact us. We can help you understand the current regulations under the Hazardous Products Regulations (HPR). We will provide an SDS and complimentary label that use the appropriate symbol. 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
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.