In early 2023, the Government of Canada published amendments to the Hazardous Products Regulations (HPR) to incorporate elements of the 7th and 8th revisions of United Nation’s Globally Harmonized System for the Classification and Labelling of Chemicals (GHS). The amendments to the HPR are meant to address issues with the previous HPR requirements, to improve health and safety communication with workers, and to maintain alignment with the Hazard Communication Standard in the United States as facilitated by the Regulatory Cooperation Council. These updates will affect how chemicals are classified and what information is required on safety data sheets (SDSs) and labels.
The updates to the HPR will include the following effects on substance & mixture classification:
1. Adoption of subcategories for flammable gases category 1
a. Pyrophoric gases now fall under the category of flammable gas category 1A and the hazard class “pyrophoric gas” is obsolete
2. Changes to the aerosol hazard categories to adopt the Aerosol Category 3 hazard category
3. Subcategorization of carcinogenic, reproductive toxicity, and germ cell mutagenicity to be permitted when information is available
4. Where a substance is both acutely toxic by inhalation and a water activated toxicant, the classification of the mixture or substance shall be based on the form as sold or imported
The changes to the HPR will also implement the following changes to Canada SDSs and labels:
1. The hazard statement “May form explosive dust-air mixture” will now be permitted for combustible dust hazards to reduce variance with OSHA safety data sheets
2. Additional precautionary statements for pyrophoric solids and liquids must be included on the label
3. The combining of hazard statements and precautionary statements is permitted on SDSs and labels
4. Less severe symbols, signal words, and/or hazard statements are no longer required on SDSs or labels if more severe warnings are required
5. Narrower ranges than the specified prescribed ranges may be used if they fall within one of the prescribed concentration ranges
6. All hazardous ingredients that are present in a mixture above the relevant cutoff level must be disclosed, regardless if the are contributing to the overall hazard of the mixture
7. Modification to section 9 information requirements
8. The date of significant new data and indication of changes must appear in section 16
How long will manufacturers/importers have to update their SDSs/labels?
The HPR amendments must be implemented in your safety data sheets by December 14, 2025.
When will the United States be updating the Hazard Communication Standard?
The US Occupational Safety and Health Administration released a notice of proposed rulemaking a couple years ago regarding plans to update the Hazard Communication Standard to GHS revision 7 with a public comment period ending in May 2021. A final rule was expected for spring 2023, but no official update has been released yet.
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