UPDATE: On the same day as the original date of publication of this post, Health Canada granted extensions to WHMIS 2015 transition timelines. This post has been updated to reflect the new changes.
In this edition of the Weekly Compliance Digest, we cover Canada’s national hazard communication standard on chemical products.
Workplace Hazardous Materials Information System (WHMIS) 2015
What is it?
On February 11, 2015, the Government of Canada published the Hazardous Products Regulations (HPR), which, in addition to the amendments made to the Hazardous Products Act (HPS), modified the Workplace Hazardous Materials Information System (WHMIS) 1988 to incorporate the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for workplace chemicals. This modified WHMIS is referred to as WHMIS 2015.
In Canada, the Workplace Hazardous Materials Information System (WHMIS) is the country’s national hazard communication standard. The key elements of the system are:
- Hazard classification
- Cautionary labeling of containers
- Provision of Safety Data Sheets (SDSs)
- Worker education and training programs.
With the incorporation of GHS, WHMIS 2015 includes new harmonized criteria for hazard classification and new requirements for labels and SDSs.
WHMIS is in a period of transition between two hazard communication regimes: WHMIS 1988 and WHMIS 2015 (which incorporates GHS). On June 1, 2018, Phase 2 of the transition period will begin, instead of the original date of June 1, 2017, following an extension granted by Health Canada.
Who is affected?
Under Phase 1 of the transition period, which will end on May 31, 2018, manufacturers and importers of hazardous chemical products have the option of complying with the previous WHMIS 1988 standard OR WHMIS 2015 (which incorporates GHS). This will change with Phase 2.
As of June 1, 2018, manufacturers and importers of hazardous chemical products will have to comply with WHMIS 2015 (which incorporates GHS). Complying with the previous WHMIS 1988 standard will no longer be an option as of that date. However, distributors will still have the option of complying with the previous WHMIS 1988 standard or WHMIS 2015 until August 31, 2018 when Phase 2 ends (Phase 3 will begin on September 1, 2018).
What are the requirements?
WHMIS 2015 incorporates GHS. There are many differences compared to the previous standard, including:
- New GHS formatted labels for chemical products
- Standardized pictograms for labels and SDSs
- Standardized hazard classes
- Harmonized criteria for hazard classification
If it’s not done already, manufacturers and importers will have to perform the following according to the provisions of WHMIS 2015 and Canada’s adaptation of GHS:
- Re-classify substances and mixtures as per the hazard classes and criteria for hazard classification included in WHMIS 2015
- Create new labels as per the new format and requirements specified by WHMIS 2015
- Author new SDSs as per the new format and requirements specified by WHMIS 2015
For more information, see the WHMIS 2015 infographic from 3E Company and Health Canada’s WHMIS 2015 – New Hazardous Products Regulations Requirements webpage. A technical guidance on the requirements is also available.
Finally, it’s worth noting that SDSs and labels compliant with the U.S. Hazard Communication Standard (2012) may not be sufficient for compliance in Canada. Organizations must be compliant with the Canadian requirements, despite the efforts by the U.S. and Canada to align their hazard communication standards as much as possible and their implementations of GHS.
What is next?
The transition between WHMIS 1988 and WHMIS 2015 is composed of three phases. Here is a summary of the transition phases from Health Canada’s webpage:
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