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Wednesday, January 2, 2019
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New amendments to the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation clarify what information companies placing nanoform substances on the market must provide in their registration dossiers. The new rules apply as of 1 January 2020.

Nanomaterials are chemicals substances with specialized features at the nanoscale, between 1 nm and 100nm. They have a wide variety of applications such as in catalysts, electronics, and medicine. The features of a nanomaterial can influence the hazards associated with it. Scientific evidence demonstrates that the toxicity and environmental effects of nanomaterials may differ from that conventional form of the substance. 

Since REACH came in to force, nanomaterials have been subject to the regulation. However, until recently it did not contain any specific requirements pertaining to these unique chemical substances. Now, companies will have to determine whether the new information requirements apply to their compounds. This is relevant for companies manufacturing or importing into Europe nanoforms of substances which fall within the scope of REACH. Nanomaterials are defined in the European Commission’s recommendation for a definition of a nanomaterial.1

ECHA has stated that it “strongly encourages” registrants of nanomaterials to become familiar with the new provisions and assess what steps must be taken in order to comply. ECHA is currently evaluating whether to update existing guidance or issue new guidance to help registrants comply with the new requirements.

In June 2017 ECHA launched its EU observatory for nanomaterials (EUON).2 This public website aims to improve availability of information about nanomaterials on the EU market. 

 

1http://ec.europa.eu/environment/chemicals/nanotech/faq/definition_en.htm

2 https://euon.echa.europa.eu/

Friday, December 21, 2018
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The government of Canada has concluded that talc may be harmful to human health and therefore meets the criteria set out in paragraph 64(c) of CEPA (Canadian Environmental Protection Act). Based on information presented in the draft screening assessment,1 it has been proposed to add talc to the List of Toxic Substances (Schedule 1 of CEPA). The proposed risk management actions are outlined in the risk management scope.2

According to evidence presented in the draft screening assessment, there is a low risk of environmental harm due to talc. With respect to human health, no critical health effects were identified via oral and dermal exposure routes. Given the limited scope of Canadian talc production, inhalation exposure from industrial and commercial uses was also not identified to be of concern. The primary focus of the assessment is on inhalation and perineal exposure to self-care products containing talc.

Non-cancer lung effects of talc have been identified as a critical health effect for risk characterization. Additionally, human studies in the peer-reviewed literature indicate a positive causal association between perineal exposure to talc and ovarian cancer. Given that there is potential for exposure from the use of various self-care products, talc has been identified as a potential concern for human health.

The Government of Canada has outlined suggested risk management actions for talc should the proposed conclusion be confirmed in the final screening assessment. Measures include the prohibition or restriction of talc in certain cosmetics which can be inhaled or used perineally. This would be accomplished by modifying the existing entry on Health Canada’s Cosmetic Ingredient Hotlist. Additionally, measures to reduce exposures from talc in certain natural health products and non-prescription drug products which can be inhaled or used perineally may be accomplished by modifying the existing entry in the Natural Health Products Ingredients Database. Finally, communications to the public to help avoid inhalation and perineal exposure to talc have been proposed.

Comments with respect to the publication may be submitted to the Minister of the Environment until February 3rd, 2019. Stakeholders are encouraged to provide information pertaining to talc that may help inform the next steps. This may include new or planned manufacture, import, or use of the substance that has not yet been reported.

 

1https://www.canada.ca/en/environment-climate-change/services/evaluating-...

2https://www.canada.ca/en/environment-climate-change/services/evaluating-...

 

Monday, November 12, 2018
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In a referendum on 23 June 2016, 51.9% of the participating UK electorate voted in favor of leaving the European Union (EU). On 29 March 2017 the United Kingdom notified the European Council of its intention to withdraw from the European Union, prompting a negotiating process to establish a Withdrawal Agreement by 29 March 2019.

Known popularly as “Brexit”, the decision of the UK to exit the EU has left many wondering how this will affect their European business dealings. With the deadline only months away, there are a couple possible outcomes: The UK could negotiation a bilateral agreement with the EU or it could fully separate and become a “third country” to the EU.

Negotiations are ongoing; however, it is unclear if the UK and the EU will come to an agreement on a Brexit deal. Previously, the UK government seemed confident that there would be a deal. However, recent developments have casted doubt on this assertion.

This year, the UK has published technical reports stating what would happen in the event of no deal. Included in these reports are advice on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH); Classification, Labelling and Packaging (CLP); and Prior Informed Consent (PIC) Regulations.

In the event of a ‘no deal’ scenario, the Health and Safety Executive (HSE) would act as the British CLP competent authority and companies operating in the UK would deal directly with the HSE. Companies importing chemicals into the UK from European countries would be considered importers under CLP and be required to comply with importer obligations. Existing harmonised classification and labelling for chemicals would continue to have legal effect in the UK. However, following withdrawal from the EU they would be free to implement new provisions for mandatory classification and labelling. UK companies will be required to use new IT tools provided by the HSE including a substance list for mandatory classification and labelling as well as a notification database. British companies registered with REACH will need to transfer their registrations to an organization based in the European Economic Area (EEA) to continue selling their products in Europe.

The UK is using a “lift and shift” approach to updating their legislation in preparation for Brexit. The idea is to “lift” each EU regulation and transpose it into UK law. However, this is not a straightforward process as some things will need to be revised. Many EU laws such as REACH regulation rely on EU infrastructure that the UK may no longer have access to.

The European Chemicals Agency (ECHA) has recently updated their advice for companies pertaining to Brexit. New Q&A’s have been included on the ECHA website on the premise that the UK will not reach an agreement prior to withdrawal on March 29th. ECHA has indicated that they will continually update their webpages as new developments unfold. Likewise, we will be sure to post updates to keep you informed as we move closer to the withdrawal date.

 

Tuesday, November 22, 2016
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The new WHIMIS 2015 program involves GHS-integrated updates to the previous WHMIS 1988, hazard communications system. As part of the newly amended WHMIS system, updated MSDS sheets are now simply referred to as SDS (Safety Data Sheets) sheets. For WHMIS 2015, updated MSDS sheets (SDSs) use the GHS standardized 16-heading format as opposed to the 9-heading format seen in WHMIS 1988; keep in mind that the headings of sections 12-15 are required in the overall format of the updated MSDS sheets but in Canada, the provision of info in these sections is optional.  The standardized 16-section format of updated MSDS sheets (SDSs) harmonizes with the internationally recognized format described in GHS’s 5th revised edition (The Purple Book) by arranging the headings in one specific order (Col 1. of Sched 1 of the HPR). A comparison between the CPR (WHMIS 1988) and HPR (WHMIS 2015) suggested M(SDS) headings and their order is outlined in the table below. 

Countries that have already adopted, or intend to adopt, the Globally Harmonized System of Classification and Labelling of Chemicals will use the 16-section format complying with the UN international regulations, which minimizes the necessity of reclassification and retesting faced by countries that use independent hazard communication systems. 

Canada’s HPR legislature specifically mandates the requirement of bilingually updated MSDS sheets (SDSs) in both the English and French language, accomplished by having French translations; within the same SDS or as a separate but identically translated copy. Also, suppliers were obligated to update MSDS sheets on a 3-year basis under WHMIS 1988 but WHMIS 2015 only requires updated MSDS sheets (SDSs) when presented with significant new data involving a hazardous products’ hazard classification and/or any changes to its handling, storage, and protective procedures. Under phase 1 of the WHMIS 1988 to 2015 transition, suppliers are granted use of either CPR or HPR compliant documents for their hazardous products; that is until the June 2017 deadline, which enforces full WHMIS 2015 compliancy. All suppliers and employers will have classified their hazardous products according to the new GHS aligned system by December 1st 2018 (transition is completed) and further ensure their workplaces have updated MSDS sheets (SDSs) and labels according to the new system. 

Please contact Nexreg for all your M(SDS) Services.

 

Monday, November 21, 2016
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OSHA SDSs, aka the Occupational Safety and Health Administration mandated safety data sheets. Originally, OSHA SDSs were known as ‘Material Safety Data Sheets (MSDS)’ as addressed in the 1994 HCS legislation but the 2012 GHS-aligned revision of HCS (HCS 2012) leaves out the ‘Material’ part. It is not simply just removing the M though, rather the OSHA SDS update imparts a change in format and content requirements, and depending on which system was previously in place, these changes are not all that different! For HCS 1994, OSHA established a set of guidelines pertaining to the previous 8-sectioned MSDS format, but it was not authoritatively implemented into federal standards, leading to variant versions from suppliers of chemical products. The American National Standards Institute (ANSI) acted on behalf of the United States in efforts to collaborate with the International Organization for Standardization in which they also put-fourth guidelines (ANSI standard Z400.1-1993), but it corresponded to a 16-sectioned MSDS format; this format being more concurrent with GHS. The format of OSHA SDSs under the revised HCS 2012 took into account the benefits of using the ANSI-internationally aligned standards, thus from June 1st 2016 and on, the only accepted format is that of GHS-HazCom 2012.

 

Manufacturers and distributors are responsible for developing SDS sheets along with labels for any hazardous chemical products they synthesize or import. It is in the hands of employers: to adequately train all employees to recognize and understand the informational elements presented on the new HCS 2012 OSHA SDSs; to provide an efficient and easily accessible means of attaining safety data sheets, as hardcopies or electronically; and to inform employees about significant updates, upon receiving updated SDSs from manufacturers or importers. Accurate and thoroughly detailed information on the safety data sheets of hazardous products used in the workplace is fundamental to competent worker-safety protection programs. Previous studies conducted by OSHA and other governing bodies brought to light the incomprehensibility of (M)SDS sheets to the everyday worker, “When experts were asked whether MSDS were too complicated for workers to understand, 92% said that they were. This reflects the opinion that the information is too technical, too complicated and too poorly organized to be useful to workers” (Metzgar, 2009, p. 26-27). SDSs provide necessary information about chemical hazards and protective procedures, but they are not specifically tailored only for use in the workplace; health care professionals, laboratory technicians, emergency responders, and etc. all comprise the diverse audience that may be seeking technical information about chemical substances through safety data sheets. It is precisely for these reasons that GHS incorporation into HCS 2012 and the standardizing of the OSHA SDS format, makes sense.

 

Ultimately, OSHA’S decision of revising the United States’ hazard communication program in alignment with GHS, benefits all those whom are confronted with handling hazardous chemical products on a daily basis. The information most important to workers or users of these chemical products can be found in sections 1-8; presenting info about the product identity, chemical make-up, associated hazards, safe-handling practices, first-aid measures, and emergency procedures within the first few sections enables users to locate it rapidly. Sections 9-11, and 16, are more technically specific, presenting to readers all related scientific data including a products intrinsic chemical and physical properties, toxicological data, its stability and reactivity, and other jargon heavy content. No content is required under sections 12-15, but their headings are to still be included, so as to maintain uniformity of the OSHA SDS format with the GHS mandated format. 

 

Thursday, November 17, 2016
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At some point in your life, you probably had to memorize and learn the WHMIS hazard symbols, whether it be for workplace safety training or for your grade 10 science class. It may have felt seemingly daunting to learn 9 distinct symbols related to chemicals you would never encounter, but the recognition and knowledge of these WHMIS symbols, continues to be a necessity for employers to ensure safety standards are met in the Canadian workplace. The introduction of WHMIS 2015 includes revisions to the WHMIS symbols, we have worked hard to familiarize ourselves with; luckily the images representing each hazard have not entirely changed. WHMIS symbols are now contained within a square sitting on one of its points instead of a circle, the border colour is red instead of black, and the symbols themselves are also black. Other distinct changes involve the hazard classes being represented by these symbols or the addition of new symbols including ‘exploding bomb’, ‘health’ and ‘environmental’ (not required in Canada) symbols. The ‘Biohazardous and Infectious Materials’ symbol has not changed from WHMIS 1988. The WHMIS symbols comparison chart below describes the differences. 

WHMIS

To comply with the new changes given to WHMIS symbols companies and businesses should keep these things in mind:

 

  1. WHMIS 2015 refers to the use of symbols as pictograms: a graphical composition with graphical elements such as specific symbols, borders, and colouring
  2. Hazardous products that affect the health of an individual are classified under the health hazard group and depicted by a black, shaded-in, human figure with a white, star-design located on the chest. Its combination with the exclamation mark symbol indicates that hazardous products were placed in the less severe sub-categories for specific health hazards
  3. Division 1 (D1) of ‘Poisonous and Infectious Materials’ for hazardous products that cause immediate death or acute toxicity (oral, dermal, or inhalation), retains the skull and bones depiction seen in WHMIS 1988
  4. The T symbol representing ‘Materials Causing Other Toxic Effects’ in Division 2 (D2) of the ‘Poisonous and Infectious Materials’ has been removed. The exclamation symbol now represents less-severe acute toxicity hazards (oral, dermal, or inhalation)
  5.   The dangerously reactive ‘R symbol’ has been removed and and is now depicted by a flame symbol, explosion symbol or a combination of both these WHMIS symbols; these symbols are used to identify products classified into the self-reactive or organic peroxide hazard classes.
  6.   Where the skull and bones symbol is used to depict hazardous products that cause toxicity, one can assume the hazard risk is severe, and acute (small concentrations can cause consequential health effects).  The exclamation symbol should not be used anywhere the skull symbol is used
  7. The corrosion symbol (represented by two-hands) indicates corrosive hazards of greater severity, and thus an exclamation symbol is not to be used in-conjunction with it, for highly corrosive materials.

Portrayal of the hazards classes and categories using the pictogram system may seem confusing at first and it could take a little while to get used! Both employers and employees should familiarize themselves with how these symbols relate to the GHS-standardized classification method prior to the completion of the WHIMIS 2015 transition. Ultimately, the GHS pictogram modification to WHMIS symbols further constitutes Canada’s efforts in regulating chemical products on a more global-scale, reducing costs for both in-house and foreign suppliers and users of these hazardous products. 

 

Wednesday, November 16, 2016
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What is GHS? This is a question many Canadians have been asking in light of the GHS based WHMIS 2015 update. The Globally Harmonized System of Classification and Labelling of Chemicals serves to provide a unified system that protects workers on a global scale, allowing for a hazard communication system that is recognized universally. As chemicals continue to be traded, distributed, and handled worldwide, persons in developed and developing nations encounter chemicals daily – as such the dangers of handling chemicals becomes a reality for them. The United Nations recognized the importance of educating people on the use of hazardous chemicals, with great consideration given to countries lacking the proper infrastructure needed to adequately educate the working population. 

 

What is GHS’s Overall Global Objective?

  1. To implement a common labelling system with consolidated hazard communication requirements.
  2. To simplify import/export procedures by eliminating the need for retesting and reclassification so that costs are reduced for businesses and consumers.

The first edition of the GHS was published in 2003, with updates and revisions being released on a 2-year basis; the 6th revised edition being the most recent. The implementation of GHS worldwide has allowed for the provision of accurate and consistent information: to identify and understand chemicals and their hazards; prevent and protect people and the environment from hazards associated with these chemicals; and finally to govern and regulate chemical trade and transport within global communities.  

 

What is GHS’s role in the trade of hazardous products between Canada and the United States? March 26, 2012 brought-forth the official adoption of GHS in the United States. The Occupational Safety and Health Administration’s (OSHA) extensive Hazard Communication Standards (HCS) program was modified to adhere to the GHS guidelines introduced by the United Nations, which has already been adopted by numerous countries internationally. Health Canada governed the reformation of Canada’s WHMIS system to meet the criterion set-out by the GHS (5th revised edition), and as such introduced the Hazardous Products Regulations (HPR) in place of WHMIS 1988’s Controlled Products Regulations (CPR) to enact these new amendments. To simplify the supply and trade of chemical products between Canada and USA, the HPR – WHMIS 2015 – aligns with OSHA’s HCS 2012 hazard classification and communication requirements – having only a a few minor differences (see WHMIS GHS vs HazCom GHS – What Makes Them Different? for more details). The hazard classification and communication requirements for hazardous products can now be fulfilled using a single combined label and combined SDS, as long as the regulations of each country are met – thus establishing greater cooperation between the two bodies as sought out by the Canada-U.S. Regulatory Cooperation Council (RCC). To learn more about the elements of GHS and WHMIS, take a look at the Glossary Termspage.

 

Thursday, November 10, 2016
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The all familiar cross-hatched border, labelling requirement ceases to exist as per the newly amended WHMIS label requirements for WHMIS 2015. The Globally Harmonized System of Classification and Labelling of Chemicals forms the basis to which Canada’s Hazardous Product Regulations is built upon. The HPR, replaces the now repealed Controlled Products Regulations, introducing a more systemic approach to protecting the users of hazardous products in the workplace. WHMIS 2015’s alignment with GHS, modifies Canada’s hazard communication system such that the information about potential hazards and any needed precautionary measures are relayed in a more recognizable and easily understood manner. WHMIS label requirements are most notably affected by the update; with some previous informational elements being excluded, others retained, and several GHS-aligned ones being added. Employers’ on-going use of WHMIS 1988-labelled, hazardous products may continue within the workplace up until December 2018; at this point, full compliance by suppliers, distributors, and employers will be required, as per completion of WHMIS 2015’s, 3-phase transition.

 WHMIS distinguishes between two main label types, supplier and workplace. Supplier labels are used on products that are received at workplaces in their original containers whereas workplace labels are applied to products manufactured in or transferred to other containers within the workplace, or, for products whose labels, lose legibility overtime. WHMIS label requirements for supplier labels under WHMIS 1988 are compared and contrasted with the requirements of WHMIS 2015:

1. Product Identifier

a). WHMIS 1988 brand name, code name, or code number specified by the manufacturer or the products chemical name, common/generic name, or trade name; both of which must be identical to the product identifier on  the MSDS. 

b). WHMIS 2015same as 1988, but only the latter part.

2. Supplier Identifier 

a). WHMIS 1988- identity of the original manufacturer or packager of the product (company name).

b). WHMIS 2015- name, address and telephone number of Canadian manufacturer or importer for the product.

3. 

a). WHMIS 1988

i. Hazard Symbols- symbols prescribed by WHMIS based on its specific hazard classification.

b). WHMIS 2015

i. Pictograms GHS prescribed hazard symbols enclosed within a red diamond. Includes the previous symbol for Biohazardous infectious material prescribed exclusively by WHMIS.

4.

a). WHMIS 1988

i. Risk Phrases- statements identifying the hazardous nature of the product based on its classifications.

b). WHMIS 2015

i. Hazard Statements- GHS-prescribed, standardized phrases that explain the significant hazards associated with a product, based on its specific categorization within a hazard class.

ii. Signal Words- Alerts user to the degree of hazardous potential by prominent display of either ‘Danger’ or ‘Warning’ depending on the severity of the hazard.

5. Precautionary Measures/Statements

a). WHMIS 1988- information on how to safely handle (PPE), store, and dispose of hazardous chemical products.

b). WHMIS 2015- GHS standardized phrases describing preventative and protective measures and procedures to prevent or minimize hazards resulting from the accidental exposure or misuse of hazardous chemical products.

6. First Aid Measures

a). WHMIS 1988-measures to be taken immediately in response to accidental exposure of hazardous chemical products.

b). WHMIS 2015- first-aid measures are included as part of the standardized precautionary statement.

7.

a). WHMIS 1988

i. Reference to Material Safety Data- directs reader to MSDS for in-depth information on product .

b). WHMIS 2015

i. Supplemental Label Information- all other information is added at the discretion of the manufacturer or supplier; given that it significantly affects the hazard classification(s) or alters what needs to be communicated.

It is important to note that even with adoption of GHS, English-French bilingualism is still required as part of the updated WHMIS label requirements.  The bilingual requirement in WHMIS 2015, can be fulfilled, using one bilingual label, or 2 identical labels that differ only by their language. The image below presents an example of a label that is fully compliant with the criterion of the GHS-aligned, WHMIS label requirements for WHMIS 2015.  

For more information regarding WHMIS 2015 Label Requirements, please contact Nexreg.

Monday, November 7, 2016
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OSHA’S Right to Know Program is a program crafted to specifically protect American men and women from the disposition of workplace hazards. OSHA – Occupational Safety and Health Administration, being the federally appointed labour agency, serves as the leading organization in development and maintenance of safety regulations and policies. OSHA’S Right to Know Program works in full-fledge support of American workers by mandating to employers, the legal obligation to inform employees about past, present, and future hazards associated with their given workplace; in fact, to withhold this information would deem the employer as unlawful. The foundation for OSHA’S Right to Know Program is primed by the importance of educating and training workers on elements specified by OSHA. OSHA’S Right to Know Program mandates that workers have the right to:

  • Know about hazardous chemicals by receiving training and education in OSHA’S, Hazard Communication Standards 2012 which requires workplaces to: 1) provide information and training on hazardous chemicals; 2) keep an updated list of all chemicals present in the workplace; 3) ensure all hazardous chemicals and their containers are correctly labelled in accordance to HCS 2012, 4) make sure chemical safety data sheets are up-to-date and that employees are aware of their location
  • Be given personal protective equipment (PPE) at no additional cost given that the work environment poses risk to the employee; examples of PPE may include goggles, earplugs, gloves, head-gear and etc.
  • Know the laws and rights that support them by having the OSHA, Job Safety and Health, “It’s the Law” poster hung up at the forefront of the workplace, made visible to all workers.
  • Be informed about past workplace injuries & illnesses by receiving copies of OSHA Form 300 records. Employers are obligated to report illnesses and injuries of serious nature; ones which require medical attention, result in decreased work-loads, or lead to time-off work for recovery. These records provide workers with greater insight into their workplace injury rate, allowing them to better prepare for and/or prevent such hazards
  • Know about exposure data that has potential to adversely affect the work environment. Employers are to routinely test for the presence of hazardous substances such as lead and asbestos. Other occupational hazards requiring routine assessment include radiation levels or constant exposure to loud-noise.

 Overall, the intent and implementation of OSHA’S Right to Know Program allows workplaces to better protect their employees by finding and fixing hazards, such that workplace illness and injury can be both prevented and reduced.

 

 

Monday, October 24, 2016
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In 2015, 5.8 % of all manufacturing jobs in Canada revolved around the industrial chemical(s) sector. 87,500 Canadian workers are employed in 525,000 chemistry related fields, a number that will continue to grow given Canada’s role as the 2nd largest exporter of manufactured chemicals. This 2016 CIAC (Chemistry Industry Association of Canada)-released economic report also emphasizes how chemical trade contributes $53 billion dollars to Canada’s economy; $38 billion of which is attributed to the worth of chemical products being exported globally. Canada takes on a leading role when it comes to protecting all parties involved in the manufacturing, distribution, supplement, and sale of hazardous chemical products. WHMIS (Workplace Hazardous Materials Information System) is Canada’s workplace safety protection program; put in place to educate and train employees on how to safely handle, store, and dispose of hazardous chemical products in the workplace. Employers are legally obligated to comply with WHMIS regulations and as such are responsible for ensuring employees can recognize and understand the informational elements of chemical labels and (M)SDS’S for hazardous materials present in the workplace.

 

Document translation services arise from efforts to strengthen the availability of chemical information in an easily accessible, accurate, and well-communicated format.  When hazardous products are exported to foreign countries, the handlers of these products in those jurisdictions require protection from workplace hazards just the same as the country of import. A direct language translation of labels and (M)SDS’s in that country’s language may seem compliant but companies risk potential fines and lawsuits if these hazard communication elements are not adjusted according to the regulatory legislations of that foreign body. Document translation services reduce this liability by not only translating, but also formatting the (M)SDS’s and labels in accordance to the jurisdiction for where the hazardous product is being supplied.

 

 Clients that use document translation services are assured fully compliant documents, thanks to the quality assurance of using certified experts.  A professional document translation services team, consists of articulate, proficient writers that have in-depth knowledge of the chemical-industry; this enables them to use industry related terminology, as they update all necessary documents in accordance with the specified jurisdictions most current regulations. Document translation services also considers whether to format labels and (M)SDS’s using a globalized (GHS – Globally harmonized system of Classification and Labelling of Chemicals) or more localized approach (ex. India’s, National Chemical Policy 2012) which ultimately affects how a hazardous product is classified, the formulas used for its classification, and which informational elements are to be included or excluded from these documents.

            Ultimately, the use of document translation services benefits all parties involved in the handling of hazardous products; manufacturers, distributors, suppliers, and employers have reduced liability to lawsuits and regulatory fines by supporting worker safety protection programs in other jurisdictions and thus removing language barriers that would have contributed to hazard miscommunication.

Nexreg compliance continues to be the leading choice for full-service document translation services of both industrial and consumer chemical products. With access to exclusive third-party data bases and authoring software, Nexreg guarantees the use of only the most up-to-date industry and government information. Furthermore, Nexreg’s commitment to completing regulatory needs in a timely fashion continues to dominate the document translation services industry by maintaining high document turnaround rates and providing RUSH service options. To uphold necessary safety measures, a clientele’s regulatory documents are safeguarded through binding contracts and protected by encrypted IT-backed servers being closely monitored by trained IT professionals.

 

To inquire about our document translation services, please visit our contact page!

 

Monday, October 17, 2016
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 “What does GHS stand for?” This popular question has been in the Canadian lime-light recently, given how phase 1 of the WHMIS 2015 transition has been underway as of February 2015. The literal translation of this popular acronym is ‘Globally Harmonized System of Classification and Labelling of Chemicals.’

What does GHS stand for globally? ‘Stand for’ in this context relates to how GHS is both implemented and represented on a nation-to-nation basis. On an international level, the GHS is a comprehensive system enforced by the United Nations to protect workers worldwide from the dangers associated with hazardous products. A consistent infrastructure for hazard classification and identification procedures, relies on the use of standardized-- hazard symbols, labels, and SDSs, such that the hazardous product requirements of global communities vary only to a minimal extent. An important objective of the United Nations is to consolidate the trade and use of hazardous products world-wide, thus they highly encourage the many nations of the world to refine their labour laws to include GHS hazard communication standards.

What does GHS stand for, in context of WHMIS 2015? WHMIS (Workplace Hazardous Materials Information System) is Canada’s federally executed worker safety protection program, set-up to educate and train employers and employees alike on the safe use and handling of hazardous products in the workplace. Canadians were likely unaware of GHS’s existence prior to WHMIS 2015’s phase 1 implementation. GHS is not explicitly contained in WHMIS 2015’s title but rather manifested and adopted in its legislations and regulations. The sole purpose of this update seeks to incorporate the regulations set out by the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals for alignment with other countries including Australia, Japan, The United States, China, New Zealand and many of the European Union members. The WHMIS 1988 to 2015 transitional, 3-phase, time-table, marks December 2018 as the date of phase 3 completion. By December 2018, GHS will be fully integrated into WHMIS legislature and no longer should there be any hazardous products containing old WHMIS 1988, labels and SDSs in Canadian workplaces. 

Tuesday, October 11, 2016
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Did you know that approximately 72 countries have already implemented- or are in the process of implementing, the Globally Harmonized System of Classification and Labelling of Chemicals into their existing labor legislations? The idea of a universally compatible classification and communication systems for chemical products was initially brought up in the 1992 United Nations Conference on Environment and Development (UNCED, 1992) with the 2002 release of its 1st published draft of regulations, ‘The First Edition of GHS (GHS Rev.1).’ The biennial updating of GHS has lead to release of The 6th Revised Edition of GHS (GHS Rev.6) which even further ensures that the system is ready for world-wide implementation.  

 GHS compliance dates are quite variable across the many different countries who are still in the progress of transitioning into a GHS compatible system. The United States is the first of Northern American nations to have fully implemented the GHS system into their labour legislation. Under guidance from America’s Occupational Safety and Health Administration, the GHS-aligned modifications to their Hazard Communication Standards (HCS) program occurred via a 3-phase, transitional process that came to completion on June 1st, 2016. Upon initial introduction of the HCS 2012 program, a time-line of GHS-compliance dates was released in which chemical manufacturers, importers, distributors, and employers were expected to meet the set deadlines. Canada similarly followed suite, given America’s success in implementing GHS via a phased-in transition.

 Canada enacts its labor laws through the federally regulated, Hazardous Products Act (HPA), and Hazardous Products Regulations (HPR), amendments. Provinces and territories, then enforce these regulations in alignment with the Occupational Health and Safety Acts of their independent jurisdiction. Provinces and territories must be synchronized in how they meet the GHS compliance dates; a 3-stage, multi-transitional time-frame for national implementation will allow independent jurisdictions to adjust their legislations in compliance with WHMIS 2015. Enactment of WHMIS 2015 via a 3-stage transition period follows closely to HCS 2012’s phased-in transition, in the United States; trading partners and stakeholders are given time to adjudicate their systems according to the new regulations, time is given to workers and employers such that they can increase their understanding and awareness of the GHS-aligned hazard communication system, and finally the use of WHMIS 1988 labels and MSDS’S can be gradually phased out of workplaces. The GHS compliance dates for Canada are outlined in the table below taken from the Health Canada website.

 Mexico, the last of 3 main Northern American nations, only recently released the ‘Harmonized System for the Identification and Communication of Hazards and Risks of Hazardous Chemicals in the Workplace’ (NOM-018-STPS-2015), an amendment entailing new GHS-aligned standards (based on 5threvised edition of GHS) to be implemented in the workplace. Once again, certain requirements are to fulfilled in alignment with their GHS compliance dates; this 3-year, transitional time-line will commence on October 2018 in which compliance with the new standards are mandatory. Adoption of GHS amongst these 3 neighbors will simplify chemical trade between these nations and further increase the protection of workers due to GHS-harmonization of information presented on hazardous products. Several other countries are approaching or have already approached their final GHS compliance dates including Japan, Singapore, Thailand, Argentina, Vietnam, the Philippines, and the EU. 


GHS Deadline

 

Tuesday, September 27, 2016
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MSDS/ SDS Preparation

Information that you must contain on you (M)SDS.

  1. Identification
  • Product Identifier:
  • This is the specific name of your product
  • Any other means of identification.
  •  For example, the family that the product belongs to
  • Recommended Use of the Product
  • Restrictions of use for the product
  • The countries supplier and identifier.
  • This includes the Name, address and phone number of the supplier
  • An emergency telephone number(s) and any restrictions on the use of the number that is provided.

2. Hazard Identification

  • The Hazards Classification
  • This includes the class and category of the particular substance or mixture OR a description of the identified hazard for Physical or Health Hazards.
  • All the label elements
  • Signal image or the name of the symbol
  • Signal word
  • Hazard Statement(s)
  • Precautionary Statement(s)
  • Any other particular hazards that do not result in classification

3. Composition/ Information on ingredients

  • Information you must provide if the hazardous product is a material substance:
  • Chemical name
  • Common name of the chemical and any synonyms
  • Chemical Abstract Service (CAS) registry number and any unique identifiers
  • Chemical name of impurities, stabilizing and/or additives
  • For each of the material or substance in a mixture that is classified in a health hazard class
  • Chemical name
  • Common chemical name and its synonyms
  • CAS registry number and any unique identifiers
  • Concentration 

4. First-aid measures

  • The first-aid measures MUST be by route of exposure

o Inhalation

    o Skin contact

      o Eye contact

      o Ingestion

      • Most important symptoms and effects (acute or delayed)
      • Immediate medical attention and special treatment 

      5. Fire-fighting measures

      • Suitable extinguishing media
      • Unsuitable extinguishing media
      • Specific hazards arising from the hazardous product
      • Special protective equipment and any other precautions for fire fighters. 

      6. Accidental release measures

      • Personal Precautions, protective equipment and emergency procedures
      • Methods and materials for containment and cleaning up. 

      7. Accidental release measures

      • Personal Precautions, protective equipment that would be needed and emergency procedures.
      • Conditions for safe storage (including incompatible materials). 

      8. Exposure controls/Personal Protection

      • Control Parameters, including any biological exposure limits or occupational exposure guidelines
      • Individual Protection measures
      • Appropriate engineering controls. 

      9. Physical and chemical properties

      • Appearance (physical state, colour, etc)
      • Odour
      • Odour threshold
      • pH
      • Melting point/ freezing point
      • Initial boiling point/ boiling range
      • Flash point
      • Evaporation rate
      • Flammability
      • Lower flammable/explosive limit
      • Upper flammable/explosive limit
      • Vapour pressure
      • Vapour density
      • Relative density
      • Solubility
      • Partition coefficient
      • Auto-ignition temperatures
      • Decomposition temperature
      • Viscosity

      10. Stability and reactivity

      • Chemical Stability
      • The possibility of any hazardous reactions
      • Any conditions that should be avoided (e.g. shock and vibration)
      • Reactivity
      • Incompatible materials
      • Hazardous decomposition products

      11. Toxicological Information

      • Complete description about the various toxic health effects the chemical may have
      • o Any symptoms that are related to the physical, chemical and toxicological characteristics
      • o Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact)
      • o Both the immediate and delayed effects
      • o Numerical measures of toxicity

      12. Ecological Information***

      • Eco toxicity
      • Persistence and degradability
      • Bioaccumulatibe potential
      • Mobility in soil
      • Other adverse effects

      13. Disposal considerations***

      • Any information about the safe handling for disposal and methods of disposal, including any contaminated packaging

      14. Transport Information

      • All information regarding transport of the chemical
      • o UN Number
      • o UN proper shipping name
      • o Transport hazard class
      • o Packing group
      • o Environmental Hazards
      • o Transport in bulk
      • o Special Precautions

      15. Regulatory Information

      • Health, environmental, and safety regulations specific to the product

      16. Other Information

      • The date of the latest revision of the SDS

       

      For more information about SDS Preparation or Nexreg's (M)SDS Services, please contact Nexreg.

      Tuesday, September 27, 2016
      Body:

      The pictogram concept tends to be a confusing aspect of the GHS system, especially given its contextual use depending on the hazard category of a class, or specific target audience. To better aide ones understanding of pictograms, this guide serves to thoroughly explain the many GHS pictogram meanings; the starting point being defining what a pictogram actually is.

       

      The 6th revised edition of The Globally Harmonized System of Classification and Labelling of Chemicals defines a pictogram as ‘a graphical composition that may include a symbol plus other graphic elements, such as a border, background pattern or colour that is intended to convey specific information.’ In terms of GHS’s hazard communications system, pictograms are required on the labels of hazardous chemical products, consisting of exact reproductions of the GHS prescribed black hazard symbols, on a white background contained within a wide, red and square-shaped frame that sits atop a single point. Use of pictograms on (M)SDSs need not be exact reproductions of that used on chemical labels, but some representation (the identification code, a written descriptor, the black hazard symbol) of it, which is to be provided in the Hazard Identification section. GHS pictogram meanings can be dissected through analysis of the graphical illustration used, the written descriptor of each symbol, and which hazards are to be associated with the overall pictogram. GHS pictogram meanings can also be differentiated into two pictogram sets that make use of the same hazard symbols. The pictogram description above comprises the set used for labels of hazardous chemicals used in the workplace; the other set, alters its use of colour and the way in which info is represented as it instead is used for the labelling of dangerous goods that are to be transported. This guide focuses on GHS pictogram meanings for pictograms that are to be put on labels of hazardous products used in the workplace.

       

      The chart below lists which hazard classes, categories, and sub-categories are to be represented by a specific pictogram. A brief description of what the pictogram encompasses is also included.

       

      Pictograms & Descriptions of the Hazardous Symbols

      Hazard Classes/Categories

      Sub-Categories

      Flammable

      A material (gas, liquid, solid) that rapidly catches fire upon ignition or combustion

       

      Flammable Gases

      1

      Flammable Aerosols

      1, 2

      Flammable Liquids

      1, 2, 3

      Flammable Solids

      1,2

      Self-reactive Substance or

      Mixtures

      B,C,D,E,F

      Pyrophoric Liquids

      1

      Pyrophoric Solids

      1

      Self-heating substances or mixtures

      1, 2

      Substances which when in contact with water, emit flammable gases

      1, 2, 3

      Organic Peroxides

      B, C, D, E, F,

      Corrosion

      May be corrosive to metals; chemically reacts to damage or destroy other materials

      Skin Corrosion; irreversible damage to skin through chemical reactivity with substance, such that visible necrosis (cell death) causes ulcers, bleeding and bloody scabs to dermis

      Corrosive to Metals

      1

      Flammable Gases

      2

      Self-reactive substances and mixtures

      G

      Organic Peroxides

       

       

      G

       

      Skin Corrosion

      1A, 1B, 1C

       

      Serious Eye Damage

       

      1

      Gas Cylinder

      Represents any gases under pressure that are contained in a receptacle at a pressure of 200kPa or more at 20°C

      Compressed Gas

       

      Liquefied Gas

      Refrigerated Liquefied Gas

      Dissolved Gas

       

      Oxidizing

      Any gas which may combine with oxygen to cause or contribute to combustion of other material more than the air does

      Oxidizing Gases

      1

      Oxidizing Liquids

       

      1, 2, 3

      Oxidizing Solids

      1, 2, 3

      Explosives

      A reactive substance that through its chemical reactivity is capable of producing a gas that can damage the surrounding environment due to its high temperature, pressure, and speed. Pyrotechnic substances are included despite lack of gas reactivity.

      Unstable Explosives

       

      Explosives

      Divisions 1.1, 1.2, 1.3, 1.4

      Self-reactive substances and mixtures

      A, B

      Organic Peroxides

      A, B

      Health Hazard

      A chemical substance that upon exposure, may cause acute or chronic health effects as determined by statistically significant results from related studies

      Respiratory Sensitization

      1

         Germ-cell Mutagenicity  

      1A, 1B, 2

      Carcinogenicity

      1A, 1B, 2

      Reproductive Toxicity

      1A, 1B, 2

      Specific target organ toxicity following single exposure

      1, 2

      Specific target organ toxicity following repeated exposure

      1, 2

      Aspiration Hazard

      1, 2

      Environmental Hazard

      Chemical substance may contribute to disruption of aquatic ecosystems, unregulated bio- accumulation or availability,  cause consequential effects to the ozone layer

      Acute hazards to aquatic environment

      1, 2

      Chronic hazards to aquatic environment

       

      1, 2

      Skull and Crossbones - Toxic

      Can cause death or toxicity upon oral, dermal, or inhaled exposure to small amount of substance even in a short duration of time

      Acute Toxicity – Oral, Dermal, Inhalation

      1, 2, 3

      Exclamation Mark - Harmful

      Used for hazards of lower grade severity in which the adverse effects are not as consequential

       

       

      Acute  Toxicity – Oral, Dermal, Inhalation

      4

      Skin Irritation

      2, 3

      Eye Irritation

      2A

      Skin Sensitization

      1

      Specific target organ toxicity following single exposure for

      • Respiratory tract infections
      • Narcotic Effects

      3

       

       Physical Hazards

       

       

       

      Explosives

      Divisions 1.5, 1.6

      Flammable Gases

      2

      Self-reactive substances

      G

      Organic Peroxides

      G

      Health Hazards

       

       

       

      Acute Toxicity – oral, dermal, inhalation

      5

       

      Eye irritation

      2B

      Reproductive Toxicity

      • Effects on lactation

       

      Environmental Hazards

       

       

       

       

       

      Acute hazards to aquatic environment

      3, 4

      Chronic hazards to aquatic environment

       

      3, 4

       

       

      Friday, September 16, 2016
      Body:

       

      WHMIS GHS Vs Hazcom GHS – What Makes Them Different?

       

      WHMIS GHS, the acronymic title representative of the newly introduced incorporation of the Globally Harmonized System of Classification and Labelling of Chemicals into WHMIS. The GHS alignment allows Canada’s hazard communication system to now meet the international requirements mandated by the United Nations. Typically, WHMIS GHS is referenced as ‘WHMIS 2015’ in many of the resources and official documents available at WHMIS.org; Canada’s National WHMIS portal.  In the United States, OSHA (Occupational Health and Safety Administration) has already fully integrated GHS into their Hazard Communication Standards (HCS) program. Being just a modified version of HCS 1994, HCS 2012 has updated the requirements and regulations laid out in GHS’s 3rd revised edition and they are fully incorporated into the new legislature. Similar to the US, Canada has also modified their previous workplace safety program (WHMIS 1988), by choosing to adopt many of the same harmonized standards found in HCS 2012; contingencies may exist as the regulations are modelled from GHS’s 5th revised ed rather than the 3rd.  February 11th, 2015, marks Health Canada’s official publication of the HPR (Hazardous Products Regulations), made to work alongside the HPA (Hazardous Products Acts) in which the new WHIMIS GHS amendments are outlined in detail.

       

      Both Hazcom & WHMIS GHS alignment, work to deliver a more universally compatible system for identification and classification of hazardous products, mixtures, materials, and substances. A systemic approach to GHS integration, it utilizes the UN’s recommended building block method. The set of minimum GHS requirements must always be incorporated into legislation, exactly as is, while other requirements need a greater leverage in how they are to be included. Some of the fundamental GHS standards to be incorporated include: a hierarchal chemical classification procedure into physical, health and environmental hazard groups; a universally recognized, 16-sectioned SDS format; using GHS prescribed pictograms to graphically represent hazards; new format and content requirements for labels; and finally updated regulations on exemptions and trade secrets. Countries choosing to adopt GHS into their respective labour legislations can expect ease of accessibility into a more globally harmonized, chemical trading-network.

       

      Canada is still in phase 1 of its WHMIS 2015 transition, giving manufacturers and distributors the choice to comply with either 1998 or 2015 WHMIS, up until the June 1, 2017 deadline. Manufacturers, distributors, and employers already compliant with WHMIS GHS can benefit from early membership in the GHS trading-network; the costs of importing/exporting chemical products are significantly reduced for countries already GHS-compliant. Canadian suppliers of hazardous products still requiring compliancy with WHMIS 2015 must ensure:

      • Identity of products is classified as either non-hazardous or hazardous products;
      • English SDS’S and labels are supplemented by subsequent French versions, either within the same SDS/label or as separate but identical bilingual versions of these materials;
      • SDS associated with labeled hazardous product is provided to buyer of that product;
      • Additional copies of SDS’s, labels, and transaction invoices are maintained and available on request;
      • Revisions are being made to SDS’s and labels on a 90- or 180-day basis upon acquisition of new data related to the hazardous products; and
      • Hazardous information contained in SDS’s and labels are promptly disclosed to competent authorities in response to emergency situations.

       

      Hazardous products that are globally exported may be subjected to criteria different from that of Canada and as such, it is advised that companies are aware of how GHS impacts a particular country’s labour legislature and which aspects have been adopted into their local systems. Luckily, WHMIS GHS alignment in Canada, ensures that WHMIS 2015 varies minimally from and follows closely to HCS 2012’s, HazCom GHS. Procedures for import, export and the sale of hazardous products with our largest trading partner, have now been simplified. Costs are further reduced and chemical classification systems further standardized all the while maintaining the previous roles of suppliers, employers, and workers. The table below identifies where and how WHMIS GHS (WHMIS 2015) differs from HazCom GHS (HCS 2012)

       

      Overall, the Hazardous Products Regulations (HPR) enacted by Health Canada, uses the already existent HCS 2012, as the framework to form a U.S.-Canada cooperative WHMIS GHS system, which also simultaneously adheres to the hazard communication requirements of other world trading partners. In accordance with these new standards, use of a single label and SDS fulfills both Canadian and U.S. requirements for hazardous products although some regulatory discrepancies exist. Where variation occurs, additional information not otherwise specified should be addressed when creating documents pertaining to hazardous products used in these jurisdictions. More often, the import or sale of hazardous products in the Canadian workplace will require other supplementary information not otherwise included in U.S. labels and SDS’s.  Ultimately, the WHMIS GHS integrated hazard communications system, benefits both Canadians and Americans alike as:

      • Workers have an increased level of protection thanks to the universally recognized hazard communication standards allowing hazardous chemicals in the workplace to more easily be identified by both parties;
      • Common labeling systems and alignment of HazCom requirements, better facilitates cooperation in these nations’ trading procedures; and
      • The trading system between these neighboring nations is now more cost-effective as the need for reclassifying and retesting hazardous products is eliminated. 

       

       

      WHMIS 2015

       

      Language

      Bilingual – French and English

      Unilingual – Only English req.

       

      Labelling of
      Carcinogenic Mixtures

       

       

      Carcinogenic ingredients - Category 1 or 2

        

      Label and SDS Required

       

       

      Carcinogenic ingredients – Category 1 or 2

       

      Label - Optional, SDS – Required


      Category 2

       

      Label and SDS Required

       

      Supplier Identifier

      Name, address, and
      telephone #

       

       

       

      Supplier Identifier

      Imported Products

       

       

       

      • Canadian supplier identifier must appear on both label and SDS
      • Supplier identifier (U.S. preferred) must appear on label.
        • Only U.S. address and # req on SDS

       

      • Canadian importer’s name, address, and telephone # required on SDS and label
      • Imported product used in importers workplace can retain name, address and telephone # of foreign supplier on SDS and label
      • Importer’s name and address is required on SDS and label (U.S. preferred)

        This portion is subject to change depending on new government released info

       

      Hazard Statements

      Phrases that describe nature of the hazard

       

      • Hazard statements for most hazardous products required on both label and SDS
      • Wording of PHNOC, HHNOC, or BIM hazard statements are to be crafted by the supplier
      • Hazard statements for hazard classes not covered by GHS are found in Schedule 5 of the HPR
        • Hazard statements should be included for both labels and SDS’s but omission of such statements is under the supplier’s discretion, given the inappropriateness of its use
        • In HCS 2012, hazard statements associated with HNOC (Hazards not Otherwise Classified) can be excluded from label and SDS

       

       

       

      Testimonial

      International Lubricants, Inc. has been very pleased with the international regulatory compliance services that Nexreg Compliance Inc. provides to us. These services range from the generation of OSHA/WHMIS MSDS to CCCR compliance label reviews. We can rely upon the accuracy of their information and their attention to detail. In addition, their project turnaround times are excellent.
      Wayne Everett, Ph.D., International Lubricants, Inc.