Top 5 questions about GHS answered
After years of anticipation, the implementation of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is one step closer to reality in the United States (U.S.). This change has implications for Canadians and Americans alike, and raises many questions. Here are the top five questions – and the answers – that CCOHS is asked about the GHS.
1. What are Canada’s timelines for implementing the GHS in WHMIS?
This is the most common GHS question that CCOHS is asked and, unfortunately, the answer is that the implementation timelines for Canada are still unknown. Federal WHMIS regulators are working on finalizing their proposed changes to WHMIS to implement the GHS. Health Canada is expected to post detailed information on their website about how WHMIS may change, for public consultation. In addition to public consultation, Health Canada has identified these remaining steps:
- an economic analysis
- revision of the federal legislation, including the Hazardous Products Act and the Controlled Product Regulations
- revision of WHMIS regulations by the provincial and territorial governments
With Canadian laws often taking one or two years to be updated, CCOHS estimates that there won’t be new WHMIS laws until 2013 or later. Then it is expected that there will be a “transition period” for suppliers and employers to switch from old-to-new WHMIS requirements (possibly a two or three year transition period).
2. Are GHS safety data sheets (SDSs) accepted in Canada today?
Yes, they are, with a few important considerations.
For some time now the WHMIS program has had a policy to accept a number of different MSDS formats, including the 16-section GHS SDS format, in place of the 9-heading format required by the Controlled Products Regulations. However, it is very important to note that the MSDS/SDS must contain all of the WHMIS required content as specified in the Controlled Products Regulations (Schedule I, Column III). It is also important to note that the GHS hazard classification may not always be the same as the WHMIS classification and there are differences in terminology between the two systems. Therefore, care should to be taken to communicate messages that are consistent with the WHMIS hazard communication system.
3. Are GHS labels accepted in Canada today?
No, they are not. The National Office of WHMIS does not have a policy to accept GHS labels. There are some important differences in the label requirements of the two systems. For example, the WHMIS regulations require:
- the use of applicable WHMIS symbols – the GHS requires pictograms, but the pictograms are not identical to the WHMIS symbols;
- the use of a hatched border – the GHS does not require a specific label border; and
- reference to the material safety data sheet – there is no similar requirement in the GHS.
Note: It remains to be seen if the hatched border and reference to the SDS will be retained after the GHS is implemented in Canada.
4. I am a Canadian manufacturer shipping hazardous products to the U.S. How will changes to the Occupational Safety & Health Administration (OSHA) Hazard Communication Standard affect me?
This is a good question. As an exporter of hazardous products to the U.S., you will have to comply with the new “GHS” requirements of the OSHA Hazard Communication Standard when they become law. Keep in mind that a multi-year transition period is expected, so you will have time to reclassify your products and prepare OSHA GHS compliant SDSs and labels. However, depending on factors such the number of raw materials/ingredients used in your products, and the number of SDSs and labels that you must produce or update, you may want to get started sooner rather than later.
On the other hand, if you are a U.S. company shipping hazardous products into Canada, you will have to continue complying with WHMIS laws until the GHS is implemented in Canada.
5. Should I be training on the GHS now?
The primary goal of training is that all target audiences know how to recognize and interpret label and/or SDS information, and take appropriate precautions. Until the new laws come into force, you should continue to train on your existing hazard communication system (Canadian WHMIS or OSHA HazCom).
If you are an American supplier, employer, or worker, you should check the OSHA website for current information regarding implementation of the GHS in the U.S., and the new Hazard Communication Standard requirements. Training resources will likely be published very soon.
If you are a Canadian supplier, employer, or worker, the CCOHS “WHMIS after GHS” courses will help increase your awareness about potential changes. However, company-wide training is not a good idea until the possible requirements for GHS implementation into WHMIS are published.
We will keep you informed with regard to any Canadian GHS updates.