Are You Ready For WHMIS 2015?
On Feb. 11, 2015, the federal Workplace Hazardous Materials Information System (WHMIS) legislation was amended to incorporate standards set by the United Nations’ Globally Harmonized System for Classifying and Labelling Chemicals (GHS). The updated version of WHMIS, which will replace WHMIS 1988 and is referred to as WHMIS 2015, includes new criteria for the classification of hazardous chemicals and establishes new requirements for labels and Safety Data Sheets (SDS).
This Legislative Brief highlights key changes under WHMIS 2015 and the impact they may have on Canadian employers and suppliers of hazardous products.
WHMIS 2015 Hazard Classes and Categories
WHMIS 2015 identifies two hazard groups—physical hazards and health hazards. Each hazard group contains a set of hazard classes, which are determined by new rules and criteria.
These changes mean that hazardous products may be described differently than they have been in the past. Additionally, products that were not previously classified as hazardous may now be considered hazardous and therefore subject to WHMIS 2015.
Suppliers are organizations that sell or import hazardous products. Under WHMIS 2015, suppliers are responsible for labelling hazardous products that they provide to customers. A supplier label is a label that is provided or attached by the supplier on all hazardous products received at Canadian workplaces.
Supplier labels must be written in both English and French and must include the following information:
- Product identifier – the brand name, chemical name, common name, generic name or trade name of the hazardous product;
- Initial supplier identifier – the name, address and telephone number of either the Canadian manufacturer or the Canadian importer;
- Pictograms – hazard symbol;
- Signal word – a word used to alert the reader to a potential hazard and to indicate the severity of the hazard;
- Hazard statements – standardized phrases that describe the nature of the risk posed by the hazardous product;
- Precautionary statements – standardized phrases that describe measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product; and
- Supplemental label information (optional) – labels may include supplementary information deemed helpful.
Supplier labels are required to be updated when the supplier becomes aware of any “significant new data.” Significant new data is defined as “data regarding the hazardous product that changes its classification in a category or subcategory of a hazard class, or results in its classification in another hazard class or changes the ways to protect against the hazard presented by the hazardous product.”
Updates must be made within 180 days of the supplier becoming aware of the new information.
Employers are responsible for making sure that hazardous products that come into the workplace are labelled. Employers must also apply a workplace label to a hazardous product when:
- A hazardous product is produced at the workplace and used in that workplace;
- A hazardous product is transferred or the product is poured into another container; or
- A supplier label becomes lost or unreadable.
- A workplace label must include the following information:
- Product name (matching the SDS product name);
- Safe handling precautions; and
- A reference to the SDS, if available.
Safety Data Sheets
Under WHMIS 2015, 16-section SDSs are replacing the nine-section Material Safety Data Sheets (MSDS). SDSs are summary documents that provide information about the hazards of a product and advice about safety precautions.
Every product classified as a “hazardous product” under WHMIS 2015 that is intended for use, handling or storage in a Canadian workplace must have an SDS.
WHMIS 2015 requires employers to make sure that all hazardous products have an up-to-date SDS when it enters the workplace. SDSs must be made readily available to the health and safety committee and to employees who are exposed to the hazardous products.
Education and Training
Employers will be required to train workers on WHMIS 2015. Employers should revise their existing training, in consultation with the health and safety committee, to include:
- New hazard pictograms;
- New hazard classes;
- New labels and their required elements, such as signal words;
- The meaning of all signal words and hazard statements found on labels and SDSs in the workplace;
- The new SDS format and how to locate the information needed to work safely with the product; and
- Worksite-specific training on how to work safely with hazardous products.
Employers should note that they are required to maintain education and training on the WHMIS 1988 system for as long as workplace products have the old WHMIS-style labels and MSDSs.
Although the new regulations are effective immediately, a multi-phased transition period has been put into place to allow all relevant parties time to adapt to the new requirements.
From now until June 1, 2017, suppliers may use either WHMIS 1988 or WHMIS 2015 to classify and communicate the hazards of their products. Additionally, distributors have been given a period of time to clear their stocks of hazardous products and employers have been provided more time to complete the transition as well.
Contact an ALIGNED Insurance Advocate today for additional information about how WHMIS 2015 will impact your business as well as strategies to mitigate any new exposures that arise from these updated regulations.