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Workplace Hazardous Materials Information System (WHMIS): WHMIS 2015 ENFORM October 5, 2015

Workplace Hazardous Materials Information System (WHMIS ... · Workplace Hazardous Materials Information System (WHMIS): WHMIS 2015 ENFORM October 5, 2015. Outline •WHMIS legislation

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Workplace Hazardous Materials

Information System (WHMIS):

WHMIS 2015

ENFORM

October 5, 2015

Outline

• WHMIS legislation

• Exemptions

• WHMIS 1988 vs WHMIS 2015

• Proposed changes to Part 29

• Transition to WHMIS 2015

2

WHMIS 2015

WHMIS is being updated in Canada to align

with the Globally Harmonized System for

Classification and Labelling Chemicals

(GHS)

3

http://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev05/En

glish/ST-SG-AC10-30-Rev5e.pdf

WHMIS Legislation

WHMIS Legislation

WHMIS in Canada

6

WHMIS

WHMIS has three components:

7

Labels

(Material) Safety Data

Sheets

Worker Education

and Training

Underlying Legislation

• Federal (regulates suppliers of hazardous

products)

– Hazardous Products Act

– Former Controlled Products Regulations

– Hazardous Products Regulations

– Hazardous Products Information Review Act

and Regulation

• Provincial (regulates employers and

workers)

– Part 29 of the Alberta Occupational Health and

Safety (OHS) Code8

Underlying Legislation

• Federal WHMIS legislation covers:

–How hazardous products are classified

–What information must be provided

when a product is sold

• Provincial legislation covers:

–What information must be available in

the workplace

–Training and education of workers

9

Confidential Business

Information

Canada has an existing system—no changes have

been made

10

Exemptions

11

WHMIS 1988 included exemptions for:

• the requirement to provide, obtain, or

prepare a material safety data sheet

(MSDS) for some types of products

• an exemption for a supplier label in some

circumstances or

• reduced or modified information on labels

and MSDSs

WHMIS 2015 some of the exemptions have been:

• removed

• retained without modification, or

• retained with modification

12

Product WHMIS 1988 Exemption WHMIS 2015 Exemption

Wood and products

made of wood

Completely exempt Completely exempt

Tobacco or tobacco

products

Completely exempt Completely exempt

Hazardous waste Completely exempt Completely exempt

Manufactured

article

Completely exempt if will not

release chemicals during

normal use

Completely exempt if will not

release chemicals during

installation and normal use

Transportation* Completely exempt Completely exempt. If a

TDGR symbol is already

present on the container, a

WHMIS symbol is not

required also.

Flavours and

fragrances

Exempt from disclosing

chemical identity and

concentration of an

ingredient as long as a

generic name is included and

the information is accessible

via an emergency number.

No exemption from disclosure

of ingredients (except in

cases of “complex mixtures”)

*includes handling, offering for transport and transport under TDG

legislation

Product WHMIS 1988 Exemption WHMIS 2015 Exemption

Explosives Exempt from MSDS, label

but not training

Class included but still

exempt in HPA from SDS

and labels but not from

training

Cosmetics, drugs, food Exempt from MSDS, label

but not training

Exempt from SDS, label

but not training

Pesticides Exempt from MSDS, label

but not training

Exempt from SDS, label

but not training

Radioactive materials Exempt from MSDS, label

but not training

Exempt from SDS, label

but not training

Consumer products Exempt from MSDS, label

but not training

Exempt from SDS, label

but not training

Laboratory samples Exempt from MSDS, may

use modified label

Exempt from SDS, may

use modified label

Complex mixtures Use generic name for

complex mixture

Use generic name for

complex mixture.

Laboratory supply house

chemicals

Exempt from MSDS if

information on label

Not exempt

13

14

Product WHMIS 1988 Exemption WHMIS 2015 Exemption

Small containers Modified label for

containers less than 100

mL

Modified content for label

for containers less than

100 mL. Allowence to

have a label that can be

removed under normal

conditions of use if the

label interferes with the

use of the product (< 3 mL

containers)

Kits (two or more products

in one container)

No exemption Allowance for modified

label for outer packaging

as long as inner

containers have supplier

labels

Bulk shipments Exempt from labels if

information provided by

supplier on MSDS or

separately. Can provide

one MSDS for the

shipment. Exempt from

providing MSDS if one

provided previously which

is still current.

Exempt from label if there

is no container of any

sort. For bulk shipments

where there is packaging,

can provide one SDS for

the shipment. Exempt

from providing SDS if one

provided previously which

is still current.

Exemptions

• If a supplier has already complied with

WHMIS 1988, they are exempt from

complying with WHMIS 2015 during the

transition period—this also applies to an

employer

• This includes products that now fall under

WHMIS 2015, such as:

–Combustible dusts

–Aspiration hazards

15

WHMIS 1988 vs WHMIS 2015

Classification

17

WHMIS 1988

• Applies to “controlled products”

• A controlled product is any product,

material or substance which is included in

one or more of six hazard classes listed in

the Hazardous Products Act

18

WHMIS 1988 Hazard Classes

• Class A: Compressed gas

• Class B: Flammable and combustible material– B1: Flammable gases

– B2: Flammable liquids

– B3: Combustible liquids

– B4: Flammable Solids

– B5: Flammable Aerosols

– B6: Reactive flammable materials

• Class C: Oxidizing material

19

WHMIS 1988 Hazard Classes

• Class D: Poisonous and infectious material– Division 1: Materials causing immediate and

serious toxic effects

• Subdivision A: Very toxic material

• Subdivision B: Toxic material

– Division 2: Materials causing other toxic effects

• Subdivision A: Very toxic material

• Subdivision B: Toxic material

– Division 3: Biohazardous infectious material

• Class E: Corrosive material

• Class F: Dangerously reactive material20

WHMIS 2015

• Applies to “hazardous products”

• A hazardous product is any product that

meets criteria for one or more of the

WHMIS hazard classes listed in the

Hazardous Products Act

21

WHMIS 2015 Physical Hazard

Classes

• Explosives

• Flammable gases

• Flammable Aerosols

• Oxidizing gases

• Gases under pressure

• Flammable liquids

• Flammable solids

• Self-reactive

substances and

mixtures

• Pyrophoric liquids

• Pyrophoric solids

• Self-heating

substances and

mixtures

• Oxidizing liquids

• Oxidizing solids

• Organic peroxides

• Corrosive to metals

22

WHMIS 2015 Physical Hazard

Classes (Canada)

• Combustible dusts

• Simple asphyxiants

• Pyrophoric gases

• Physical hazards not otherwise classified

23

WHMIS 2015 Health Hazard

Classes

• Acute toxicity

• Skin corrosion/irritation

• Serious eye damage/irritation

• Respiratory or skin sensitization

• Germ cell mutagenicity

• Carcinogenicity

• Reproductive toxicity

• Specific Target Organ Toxicity (STOT)—single exposure

• Specific Target Organ Toxicity (STOT)—repeated

exposure

• Aspiration hazard

24

WHMIS 2015 Health Hazard

Classes (Canada)

•Biohazardous infectious materials

•Health hazards not otherwise classified

25

GHS Environmental Hazard

Classes

• Hazardous to the aquatic environment

• Hazardous to the ozone layer

These hazard classes are not

included in Canadian WHMIS

legislation

26

Product Classes: WHMIS 1988 vs WHMIS

2015

WHMIS 1988 Hazard Class WHMIS 2015 Hazard Class

A Compressed Gas Gases Under Pressure

B Flammable and Combustible

Material

B1 Flammable Gases

B2 Flammable Liquids

B3 Combustible Liquids

B4 Flammable Solids

B5 Flammable Aerosols

B6 Reactive Flammable Materials

Flammable Gases

Flammable Liquids (includes Combustible

Liquids)

Flammable Solids

Flammable Aerosols

Self Heating Substances and Mixtures

Pyrophoric Gases, Liquids and Solids

Substances Which in Contact with Water

Emit Flammable Gases

Organic Peroxides

27

WHMIS 1988 Hazard Class WHMIS 2015 Hazard Class

C Oxidizing Material Oxidizing Gases, Liquids and Solids

D Poisonous and Infectious Material

D1 Materials Causing Immediate and

Serious Toxic Effects

D2 Materials Causing Other Toxic

Effects

D3 Biohazardous Infectious Material

Acute Toxicity, Oral, Dermal, Inhalation

Eye/Skin Irritation

Respiratory/Skin Sensitization

Carcinogenicity

Reproductive Hazards

Mutagenicity

Specific Organ Systematic Toxicity (STOT)-

Single Exposure

STOT-Repeat Exposure

Aspiration Hazard

Biohazardous Infectious Material

Product Classes: WHMIS 1988 vs WHMIS

2015

28

WHMIS 1988 Hazard Class WHMIS 2015 Hazard Class

E Corrosive Material Corrosive to Metal

Skin Corrosion

Serious Eye Damage

F Dangerously Reactive Material Self Heating Substances and Mixtures

Pyrophoric Gases, Liquids and Solids

Substances Which in Contact with Water Emit

Flammable gases

Organic Peroxides

N/A Explosives (class included but still covered under

HPA exemptions for now)

N/A Combustible Dusts

N/A Simple Asphyxiants

N/A Physical Hazards Not Otherwise Classified

Health Hazards Not Otherwise Classified

Product Classes: WHMIS 1988 vs WHMIS

2015

29

30

Products that are

currently classified

under WHMIS 1988

may need to be re-

classified under

WHMIS 2015

Example: Flammable/Combustible

Liquids

B2, Flammable Liquid Flashpoint <37.8° C (100°F)

B3, Combustible Liquid Flashpoint more than 37.8°C (100°F)

and less than 93.3 °C (200°F)

WHMIS 1988 Classes B2 and B3 Flammable

and Combustible Liquids

WHMIS 2015 Flammable Liquids

Category Criteria

1 Flashpoint <23°C, initial BP ≤ 35°C

2 Flashpoint <23°C, initial BP > 35°C

3 Flashpoint ≥ 23°C and ≤ 60°C

4 Flashpoint > 60°C and ≤ 93°C

31

GHS Classification of Mixtures

Use test data for mixture

Bridging principles:Dilution

Batching

Concentration of highly toxic mixtures

Interpolation within one toxic category

Similar mixtures

Aerosols

Estimate hazards based on known ingredient

information

32

GHS Classification of Mixtures

• Legislation indicates that there is no

obligation for a supplier to test their

product

BUT

• Most of the physical hazard classes

require test data for the mixture (cannot

use data on the ingredients to classify)

• Bridging principles may only be used for

health hazard classes

33

34

Classifying mixtures is a

technically complex

process!

Labels

35

Supplier

LabelWork Site

Label

The information on the supplier label must be

provided in both English and French

WHMIS 1988 Supplier Labels

36

WHMIS 2015 Supplier Labels

• Must include the following information:

–Product name

–Initial supplier identifier

–Pictogram

–Signal word

–Hazard statement(s)

–Precautionary statement(s)

–Supplemental information (if desired)

37

WHMIS 1988 vs WHMIS 2015

Content

38

WHMIS 1988 WHMIS 2015

Product Identifier Product Identifier

Supplier Identifier Initial Supplier Identifier

Pictogram Pictogram

Risk Phrases Hazard Statement

NA Signal Word

Precautionary Measures Precautionary Statements

First Aid Statement Part of Precautionary Statement

Hatched Border No

Reference to MSDS No

WHMIS 2015 label content is

based on product classification

39

WHMIS 2015 Pictograms

40

Health Hazard Flame Exclamation

Mark

Carcinogen

Mutagenicity

Reproductive Toxicity

Respiratory Sensitizer

Specific Target organ toxicity-single

exposure

Specific Target organ toxicity-repeated

exposure

Aspiration hazard

Flammable gases, aerosols, liquids,

solids

Pyrophoric liquid, solid, gas

Self-Heating substances

Emits flammable gas in contact with

water

Self-Reactive

Organic peroxide

Irritant (skin and eye)

Skin sensitizer

Acute toxicity (harmful via oral, skin,

inhalation)

Respiratory tract irritant

Gas Cylinder Corrosion Exploding

Bomb

Gases under pressure Skin corrosion

Serious eye damage

Corrosive to metals

Explosives

Self-reactive substances and mixtures

Organic peroxides

Flame Over

Circle

Skull and

Crossbones

Biohazardous

Infectious

Material

Oxidizers (liquids, solids, gases) Acute toxicity (fatal or toxic via oral, skin,

inhalation)

Biohazardous infectious material

!

WHMIS 1988 vs WHMIS 2015

Pictograms

WHMIS 1988

Hazard Class

WHMIS 1988 WHMIS 2015 WHMIS 2015 Hazard

Class

D3 Biohazardous

Infectious Materials

E

Skin/Eye Corrosion

Corrosive to Metals

F

Self-Reactive

Substance,

Organic Peroxide

N/A N/A Explosive Substance

42

WHMIS 1988 vs WHMIS 2015

Pictograms

WHMIS 1988

Hazard Class

WHMIS 1988 WHMIS 2015 WHMIS 2015 Hazard

Class

N/A N/A

Aspiration, STOT

(Single Exposure,

Repeated Exposure)

N/A N/A N/A Combustible Dust

N/A N/A N/A Simple Asphyxiant

N/A N/A Use appropriate

symbol

Physical Hazards Not

Otherwise Classified,

Health Hazards Not

Otherwise Classified

43

WHMIS 1988 vs WHMIS 2015

Pictograms

Signal Words

“Danger” or “Warning”

•Used to emphasize hazard and to

discriminate between hazard categories

(level of hazard)—use only one

e.g. Acute toxicity category 1 requires

“Danger”, category 4 requires “Warning”

•In a mixture, use the highest level signal

word that applies based on the ingredients

44

Hazard Statements

• A single harmonized hazard statement

for each hazard category within each

hazard class, e.g. for flammable liquids:

• Category 1 “extremely flammable liquid and

vapour”

• Category 2 “highly flammable liquid and

vapour”

• Category 3 “flammable liquid and vapour”

• Category 4 “combustible liquid”

45

Precautionary Statements

• Four types:

– Prevention

– Response in cases of accidental spillage or

exposure

– Storage

– Disposal

• Listed in Annex 3 of the “Purple Book”

• May not need to include all four types for each

hazard class

46

Precautionary Statements

Example: Flammable Gases, hazard category 1• Prevention: Keep away from ignition sources

such as heat/sparks/open flames—No Smoking

• Response: Leaking gas fire

• Do not extinguish, unless leak can be stopped

safely

• Eliminate all ignition sources if safe to do so

• Storage: Store in well-ventilated place

47

What might a WHMIS 2015 supplier

label look like?

48

WHMIS 2015 Supplier Label

Example

49

Image provided by Canadian Centre Occupational Health and Safety and used with permission

Label Appearance “Musts”

• Use pictograms exactly as shown in

legislation with respect to colour and

appearance (may adjust size)

• Pictogram, hazard statement and signal

word must be grouped together

• Label must be legible, prominently

displayed, visible under normal conditions

of use, contrast with other label information

• Label must remain affixed to the container

under normal conditions of transport and

use50

Safety Data Sheets

51

Safety Data Sheets (SDSs)

• 16-heading format

• Minimum additional information

specified, where applicable or available,

under the relevant heading

• Three year review requirement removed

(information must always be current)

• Must be provided in both English and

French

52

MSDS vs SDS Content

WHMIS 1988 WHMIS 2015

Chemical Product and Company

Information

• Product identifier

• Product use

• Manufacturer name, address

• Supplier name, address

• Emergency telephone number

• Preparation date of MSDS

• MSDS preparer/telephone

• (WHMIS Classification)

Identification

• Product identifier

• Other means of identification

• Initial supplier identifier

(manufacturer/distributor)

• Emergency telephone number

Composition/Information on Ingredients

• List of hazardous ingredients and % in

product

• CAS number

• LD50/LC50

Hazard Identification

• Classification of hazardous product

• Label information

• Other hazards known to supplier

Hazards Identification

• Route of entry

• (Emergency overview)

• (WHMIS symbol)

• (Potential health effects)

Composition/Information on Ingredients

• List of hazardous ingredients (including

chemical name, common name and

synonyms)

• CAS number

• Chemical name of impurities, stabilizers,

additives

• Ingredient concentration

53

MSDS vs SDS ContentWHMIS 1988 WHMIS 2015

First Aid Measures First Aid Measures

Fire Fighting Measures

• Flammability

• Means of extinction

• Flashpoint and method

• LEL and UEL

• Autoignition temperature

• Explosion data

• Hazardous combustion products

• (NFPA classification)

Fire Fighting Measures

• Means of extinction

• Specific hazards including hazardous

combustion products

• Special protective equipment and

precautions for firefighters

Accidental Release Measures

• Leak and spill procedures

• Storage requirements

Accidental Release Measures

• Personal precautions, protective

equipment and emergency procedures

• Methods and materials for containment

and cleaning

Handling and Storage

• Handling procedures and equipment

Handling and Storage

• Precautions for safe handling

• Conditions for safe storage, including

incompatibilities

Exposure Controls/Personal Protection

• Exposure limits

• Engineering controls

• Personal protective equipment

Exposure Controls/Personal Protection

• Exposure limits with source

• Engineering controls

• Personal protective equipment

54

MSDS vs SDS ContentWHMIS 1988 WHMIS 2015

Physical and Chemical Properties

• Physical state

• Odour and appearance

• Odour threshold

• Specific gravity

• Vapour density

• Vapour pressure

• Evaporation rate

• Boiling point

• Freezing point

• pH

• Partition coefficient

• (Solubility in water)

Physical and Chemical Properties

• Physical state and appearance

• Odour

• Odour threshold

• pH

• Melting point and freezing point

• Initial boiling point and boiling range

• Flash point

• Evaporation rate

• Flammability (solids and gases)

• UEL and LEL

• Vapour pressure

• Vapour density

• Relative density

• Solubility

• Partition coefficient

• Autoignition temperature

• Decomposition temperature

• Viscosity

Stability and Reactivity

• Chemical stability

• Incompatibility

• Reactivity

• Hazardous decomposition products

Stability and Reactivity

• Chemical stability

• Incompatibility

• Reactivity

• Hazardous decomposition products

• Possibility of hazardous reactions

• Conditions to avoid (shock, static,

vibration)

MSDS vs SDS Content

WHMIS 1988 WHMIS 2015

Toxicological Information

• Effects of acute exposure

• Effects of chronic exposure

• Irritancy

• Skin sensitization

• Respiratory sensitization

• Carcinogenicity (ACGIH and IARC)

• Reproductive toxicity

• Teratogenicity

• Embyrotoxicity

• Mutagenicity

• Name of synergistic products/effects

Toxicological Information

• Concise but complete description of

toxic health effects and data used to

identify them, including:

• Likely routes of exposure

• Symptoms related to physical,

chemical and toxicological

characteristics

• Acute and chronic effects

• Numerical measures of toxicity,

including ATEs

(Ecological Information)

• (Aquatic toxicity)

Ecological Information

• Ecotoxicity (aquatic and terrestrial)

• Persistence and degradability

• Bioaccumulative potential

• Mobility in soil

• Other adverse effects

Disposal Considerations Disposal Considerations

56

MSDS vs SDS Content

WHMIS 1988 WHMIS 2015

Transport Information

• UN number

• TDG identification

Transport Information

• UN number

• UN shipping name

• UN packing group

• Environmental hazards (IMDG Code)

• Bulk transport shipping information

• Special precautions

Regulatory Information

• (WHMIS Classification)

• (OSHA)

• (SERA)

• “This product has been classified in

accordance with the hazard criteria of

the Controlled Products Regulation and

the MSDS contains all of the

information required by the Controlled

Products Regulation.”

Regulatory Information

• Safety, health and environmental

regulations made within or outside

Canada, specific to the product in

question

Other Information

• Nothing specified

Other Information

• Date of the latest revision of the SDS

57

Biohazardous Infectious

Materials

• Must have an SDS with an appendix that contains specified

information

• Section headings:

– Infectious Agent

– Hazard Identification

– Dissemination

– Stability and Viability

– First Aid/Medical

– Laboratory Hazard

– Exposure Controls/Personal Protection

– Handling and Storage

– Regulatory and Other Information

58

Proposed Changes to Part 29 of

the OHS Code

Changes to Terminology

• “Controlled Product” becomes “Hazardous

Product”

• “Material Safety Data Sheet” becomes “Safety

Data Sheet”

• New definitions

– CAS Registry Number

– Mixture

– Significant New Data

– Substance

• Definition with big changes

– Label (broader and specifies that the label must

be attached in some way to the container)60

WHMIS Exclusions

• No significant changes, except for

manufactured articles

• Manufactured articles are not exempt if

they release a chemical during installation

and normal conditions of use

61

Training

• No changes to these requirements

• Training is based on products in workplace:

– Only WHMIS 1988—train to WHMIS 1988

– Only WHMIS 2015—train to WHMIS 2015

– Products complying with both old and new systems—

must have both WHMIS 1988 and WHMIS 2015 training

• Training requirement applies as soon as employer

receives WHMIS 2015 products

• Generic training does not meet the OHS Code

requirements as there must be a site-specific component

• A worker training course on WHMIS 2015 that will meet

the “generic” component is available online from CCOHS

(http://WHMIS.org)

Label Requirements

• New requirement to update label where the

employer is provided with significant new data

from the supplier

• Removal of requirement to apply supplier labels to

individual containers in a bulk shipment (supplier

is no longer exempt)

• Removal of label exemption for products from

laboratory supply houses

• Some changes to requirements for laboratory

sample labelling

63

SDS Requirements

• Removal of three year update requirement

–Employer not required to ensure SDS is

within three years of last revision

–Employer must ensure they receive most

up-to-date SDS at time of sale

–Employer must update SDS within 90

days of receiving significant new data

from supplier

64

Confidential Business

Information

• Some changes to align with changes to

federal legislation (e.g. Health Canada now

performs the functions of the former

Hazardous Materials Information Review

Commission)

65

Transition to WHMIS 2015

Need To Know!

67

WHMIS 2015 is in

Force Now

WHMIS 2015 Supplier Transition

Periods

68

• May Comply with WHMIS 1988 OR WHMIS 2015

Manufacturer or Importer

February 11, 2015 to June

2017

• May Comply with WHMIS 1988 OR WHMIS 2015

Distributor

February 11, 2015 to June

2018

WHMIS 2015 Employer

Transition Periods

69

Phase 1

• February 11, 2015 to June 2018

• Comply with WHMIS 1988 AND/OR WHMIS 2015

Phase 2

• June 1, 2018 to December 2018

• May Comply with WHMIS 1988 for existing products, must comply with WHMIS 2015 for new products

Phase 3

• December 1, 2018

• Must Comply with WHMIS 2015

Compliance and Enforcement

• There are four key periods we need to address

1. Time before Part 29 is amended to align with

the federal legislation

2. Transition period after Part 29 is amended

until June 2018

3. Additional time for employers to use up

WHMIS 1988 products (June 1, 2018 to

December 2018)

4. After transition time is over (December 1,

2018)

70

Until Part 29 is Amended

• WHMIS 2015 is in force in Alberta even though amendments

have not yet occurred

• For employers:

– If there are only products complying with WHMIS 1988 in the

workplace, comply with WHMIS 1988

– If there are products complying with both WHMIS 1988 and

WHMIS 2015, must comply with both systems concurrently

– Can apply a WHMIS 1988 work site label to WHMIS 2015

products and just comply with WHMIS 1988 as long as SDS for

each product contains all information required by former

Controlled Products Regulations

– Ensure that worker training reflects the information products in

the workplace

71

Once Part 29 is Amended until

June 2018

• Employers must:

– Comply with WHMIS 1988 if suppliers provide

MSDSs and labels under old system

– Comply with WHMIS 2015 if suppliers provide

SDSs and labels under new system

– Comply with both systems concurrently if they

have products complying with both WHMIS

1988 and WHMIS 2015

• Key issue is that WHMIS training in the

workplace reflects the information

systems in use in the workplace

72

June 1 2018 to December 2018

• Employers:

– Can continue to use WHMIS 1988 for products

received prior to June 2018

– Must ensure that new products coming into the

workplace comply with WHMIS 2015

– Should be transitioning over to WHMIS 2015

– Must still provide training on both systems if

they still have products complying with WHMIS

1988

• If employers receive new products that do not

comply with WHMIS 2015, a referral for federal

enforcement should be done73

After December 1, 2018

• Employers should only be complying with

WHMIS 2015

– If they still have products complying with

WHMIS 1988, they must have labelling and

SDS complying with WHMIS 2015 to continue

using product, or

– Properly dispose of product

• If employers receive new products that do

not comply with WHMIS 2015, a referral

for federal enforcement should be done

74

For More Information…

75

http://WHMIS.org

Thank you!

76

Thank you