You may already be aware that the Government of Canada has recently amended the Hazardous Products Regulations (HPR) and Hazardous Products Act (HPA), which apply to hazardous chemicals used in Canadian workplaces. The changes align Canada’s Workplace Hazardous Materials Information System (WHMIS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Seventh revised edition and parts of the GHS Eighth revised edition.
This article provides an overview of the key changes that will be implemented by the 15 December 2025 deadline as well as details about how to stay in compliance.
Updates to WHMIS GHS requirements
- The new Chemicals Under Pressure – Category 1, 2, and 3 classifications have been adopted for GHS Eighth revised edition.
- Chemicals Under Pressure are liquids or solids that are packaged in a container other than an aerosol dispenser, which are pressurized with a gas at a pressure of 200 kPa or more at 20 °C.
- Aerosol products cannot be Chemicals Under Pressure.
- Changes to Flammable Gases sub-categories to align with GHS Seventh revised edition:
- Category 1 is now further divided into Category 1A and 1B.
- Category 1A can also now be subcategorized into Chemically Unstable Gas A, Chemically Unstable Gas B, and Pyrophoric Gas.
- Changes to Aerosol Classifications to align with GHS Seventh revised edition:
- Flammable aerosols – Category 1 and 2 are now Aerosols – Category 1 and 2.
- Aerosols – Category 3 is added for non-flammable aerosols.
- Aerosols are no longer required to be classified as a Gas Under Pressure, and the compressed gas GHS symbol can be removed.
- New definitions added for Chemically Unstable Gas, Flammable Gas, and Pyrophoric Gas.
- The supplemental label elements for products that release hazardous or toxic gases in contact with water have been clarified.
- Classification criteria for Organic Peroxides, Combustible Dusts, Skin Corrosion, Eye Irritation, and Specific Target Organ Toxicity – Single Exposure 3 (STOT SE3) have been refined.
- It has been clarified that it is allowable to use a concentration range that falls “entirely within” one of the concentration ranges set out in the HPR.
- Information given to the user about significant new data must detail the changes to the Safety Data Sheet and label that are required because of the new data, and not just provide the new data itself.
- References to test methods have been updated in the regulation to refer to the most recent editions.
- Various provisions have been clarified to reflect the original intended meaning of the regulations.
How to maintain compliance
Companies have been given 3 years to transition to the new regulatory scheme and ensure that all safety documents, Safety Data Sheets (SDSs) and labels, have been updated by the 15 December 2025 deadline. During the transition period, SDSs and labels created according to either the previous HPR or the amended regulations are both considered to be compliant. Health Canada is planning to release the updated Technical Guidance on the requirements of the HPA and the HPR in Spring 2023, so keep an eye out for that.
Changes to workplace labels will be needed in situations where the product classification has changed because of new or clarified classification criteria, updated test methods, or the adoption of new hazard classes.
As for your SDS, Section 2 will need to be updated with any revised label warnings, where applicable. Some of the other information elements on the SDS will need to be adjusted based on revisions to Schedule 1 of the HPR, such as the Section 9 Physical Properties, which now includes a field for particle characteristics. The new HPR regulatory reference will also need to be included.
It is recommended to update your SDS every 3 years to check for revised chemical data and hazard information. Nexreg can assist you with all your SDS and label updates with customizations to fit your business needs.
Contact Nexreg today for assistance with WHMIS GHS compliance and more!