WHMIS 2015 – What Canadian Employers Need to Know Dr. Mike Moffatt Nexreg Compliance Inc. ...

WHMIS 2015 – What Canadian Employers Need to Know

Dr. Mike MoffattNexreg Compliance Inc.

Nexreg Compliance Inc.www.nexreg.cominfo@nexreg.com

(519)488-5126

Seven Big Questions

1. What changes with WHMIS 2015?

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ANSWER: ALMOST EVERYTHING TO DO WITH SAFETY DATA SHEETS AND WORKPLACE

LABELS!

A quick review…

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What is GHS?

•U.N. Initiative: Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

•HarmonizedClassification Criteria Safety Data Sheets (SDSs) Label Elements

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Building Block Approach

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Purple Book – Up to 5th Revision.•3 Hazard Groups: Health, Physical, Enviro.•28 classes (10 H, 16 P, 2 E)•Categories (under class)

e.g. Ph: Flammable Aerosol, Category 2

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•2 Signal Words (Danger, Warning)•Combined Hazard Statements•Combined Precautionary Statements•Standardized 16 section SDS•9 Pictograms (non-transport)

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•Each jurisdiction has adopted some building blocks but not others

•Each jurisdiction has adopted non-GHS rules (EU SDS Format 453/2010, Prop 65, etc.) which must also be followed

GHS IS NEITHER GLOBAL NOR HARMONIZED!

Obtaining the Official Regulations

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A copy of the official regulations can be obtained from the Government of Canada Gazette Website:http://gazette.gc.ca/rp-pr/p2/2015/2015-02-11/html/sor-dors17-eng.php

Alternatively, Nexreg can send you a copy by e-mailing: info@nexreg.com

New HPR vs. Current CPR

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Ultimately, the Canada GHS regulations differ from current CPR in five broad areas:1. The manner of establishing the classification of

workplace hazardous chemicals2. Classification of physical hazards3. Classification of health hazards4. Hazard communication and other requirements5. Exemptions

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•The requirement from CPR for a hatched boarder around the label content was not retained

•The requirement that the label contain a statement to the effect that a material safety data sheet is available was not retained

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•The SDS must only disclose ingredients in the mixture that present a health hazard.

•Current CPR requires disclosure of ingredients: • classified as physical hazards, • listed in the Ingredient Disclosure List • believed on reasonable grounds to possibly be harmful• for which the toxicological properties are not known

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• The 3 year renewal requirement was not retained The SDS and label must be accurate at the time of each

sale or importation of the product. Anytime new information is available the documents must be re-reviewed.

Takeaway: Need to ensure your workplace has updated WHMIS 2015 SDSs and labels before

December 2018.

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Seven Big Questions

2. What are the major differences between WHMIS 2015 and US Hazcom 2015?

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Differences Between US and Canada

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•We are happy with the similarity to US Hazcom 2012 “… and is aligned with the HCS 2012”

•A handful of significant differences mostly due to some existing Canadian rules being retained

•As such, not 100% harmonization but very close

Overall Impression of the Proposed Regs’

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• “… and is aligned with the HCS 2012”

• HPR and HCS 2012 are aligned such that both can be combined onto a single document Will know more details when Health Canada releases

guidance on how to combine the two countries’ regulations onto a single document

One Area of Concern…

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Proprietary/Trade Secret Chemicals:

•Currently, Canada and US differ greatly with how proprietary/trade secret chemicals are handled.

HMIRA# vs. “withheld as a trade secret” statement Exact concentrations vs. No Set Ranges

One Area of Concern…

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Exact Concentrations vs. No Set Ranges• Canadian GHS did not retain WHMIS ranges. It has been stated that the exact % must be disclosed unless there is a known variance in the raw material or manufacturing process (or register for a HMIRA#)

• American GHS states that you can assign any chemical range desired, as long as the statement “withheld as a trade secret” appears.

Differences between USA and CAN GHS

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The following HPR label requirements are not aligned with HCS 2012:

•Carcinogenicity – Carcinogenic ingredients @ 0.1% or more required a label under HPR

•The following classifications require a label under HPR PHNOC and HHNOCs Biohazardous Infectious Materials Water Reactive Substances

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Hazard Statements

• HPR does not allow the omission of non-applicable hazard statement

• HCS 2012 allows you to remove hazard statements that do not apply

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Small Volume Containers

• Products packaged in small volume containers (<100 mL) are proposed to be exempt from the requirement to bear P or H statements on the label

• HCS 2012 does not provide such an exemption. However, OSHA addresses provisions for small package labelling in response to questions from individual suppliers

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Small Volume Containers (3mL or less)

• Products packaged in a container with a capacity of 3 mL or less where the label interferes with the use of the product are required to have a label only while in transport/storage, not during their use

• HCS 2012 does not provide such an exemption. However, OSHA addresses provisions for small package labelling in response to questions from individual suppliers

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Multiple Containers or Kits

• HPR requires that all containers in which a product is packaged has a label. An outer container that contains two or more products (such as a kit) can bare a reduced label

• HCS 2012 only requires that the immediate (innermost) container of a product to be labelled. Therefore there is no exemption for the labelling of outer containers

2. US-Canada Differences

Takeaway: Cannot just use US documents in Canada. Significant differences still exist

between the two systems.

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Seven Big Questions

3. How does WHMIS 2015 Change Requirements for Consumer Products?

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Something to keep in mind…

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GHS regulations do not affect consumer labels!

•HCS 2012 does not apply to CPSC Consumer Labels with regards to the US

•HPR will not apply to CCCR consumer labels with regards to Canada

3. Consumer vs. Workplace

Takeaway: Canada still running parallel workplace vs. consumer label regulations.

Same issues still exist with ensuring workplace chemicals meet workplace standards.

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Seven Big Questions

4. What are supplier requirements under WHMIS 2015?

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Supplier Requirements

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During the transition, suppliers can provide SDSs and labels in either WHMIS 2015 or WHMIS 1988 systems, but they must be consistent for an individual product (that is, label must match SDS).

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Manufacturers and distributors must provide WHMIS 2015 compliant documents after their respective deadlines.

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Companies can not combine WHMIS 2015 and WHMIS 1988 information on to a single document, though many will try.

4. Supplier Requirements

Takeaway: During the transition period, manufacturers/distributors can still provide SDSs and labels under old format. May be worth pressing companies to have WHMIS 2015 documents well ahead of deadline.

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Seven Big Questions

5. What Does WHMIS 2015 Require of Workplaces?

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Workplace Requirements

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During the transition period, workers will be in contact with both WHMIS 2015 and WHMIS 1988 labels and SDSs, meaning they will need to be familiar with both systems.

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As soon as the first product that is in the workplace that has an SDS and label for WHMIS 2015, workers must be trained in that system.

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Overall training requirements are provincial jurisdiction. Does not appear any province is changing the overall rules around training (of course, this is always subject to change)

5. Workplace Requirements

Takeaway: If there’s WHMIS 2015 products in workplace, workers must be trained in the new

system.

If there’s still WHMIS 1988 products in workplace, that training must continue.

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Seven Big Questions

6. What Are the Compliance Dates for WHMIS 2015?

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Canadian Proposal – June 29, 2013Canada GHS Timeline, so far…

First Proposal – June 29, 2013First Comment Period – June 29 to Sept 15, 2013 Second Proposal – Aug 8, 2014

Second Comment Period – Aug 8 to Sept 8, 2014

Canada GHS Transition Period/Implementation – Feb 2015 to Dec 2018•Health Canada has introduced a 2 year transition period (for manufacturers/importers) and a 3 year transition period (for distributors) with a final implementation deadline of Dec 1st, 2018 (for employers).

June, 2013 Sept, 2013 Aug, 2014 Sept, 2014

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Canadian Proposal – June 29, 2013Canada GHS Implementation Phases

Phase 1: Feb 2015 to May 2017 - Transition to GHS. Either old WHMIS or new GHS documents will be accepted during this time.

Phase 2: June 2017 to May 2018 – Manufacturers MUST be fully compliant with WHMIS 2015 starting June 2017. Distributors have until May 2018 to be fully compliant

Phase 3: June 2018 to Nov 2018 - All suppliers/ manufacturers/importers /distributors must follow GHS. But workplaces can continue to use up their old documents and labeled products.

Dec 2018 - full transition complete

6. Deadlines

Takeaway: U.S. experience shows that deadlines sneak up on companies. Will not

want to leave until last minute.

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Seven Big Questions

7. What Are the Biggest Challenges for Workplaces?

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Workplace Challenges

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U.S. experience very instructive. Workplaces must be vigilant that they are receiving correct documentation. Unfortunately too many manufacturers/distributors ill-informed.

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1. Ensure documentation is Canadian compliant. If unsure: ASK!

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2. Ensure documentation does not try to combine WHMIS 1988 and WHMIS 2015. If it does: REJECT.

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3. Make sure all employees are trained up in the new system before a single WHMIS 2015 product enters the workplace.

WHMIS 2015 – What Canadian Employers Need to Know

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Questions?

WHMIS 2015 – What Canadian Employers Need to Know Dr. Mike Moffatt Nexreg Compliance Inc. ...

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