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WHMIS GHS vs Hazcom GHS

Posted Date: 
Friday, September 16, 2016

 

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

Non-Slip Safety Solutions Inc would like to thank Nexreg for guiding us through the process of getting a CCCR Review on our product packaging, bottles and labels. We cannot thank you enough for working with us regarding our time frame. Due to this we were able to obtain the approval necessary to move forward with our products and they are now on the shelves of over 1,000 retail stores across Canada.
Dan George, Non-Slip Safety Solutions