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 The HPR, replaces the now repealed Controlled Products Regulations, introducing a more systemic approach to protecting the users of hazardous products in the workplace.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 2015– same 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.
