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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
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
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
• 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
Labels
35
Supplier
LabelWork Site
Label
The information on the supplier label must be
provided in both English and French
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 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
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
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 (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
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
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