WHMIS 2015: Understanding the New Safety Data Sheets

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The final Hazardous Products Regulations (HPR), which implement the GHS in Canada in the form of WHMIS 2015, make various change to the “old” WHMIS (called WHMIS 1988 now). Among other things, WHMIS 2015 replaces material safety data sheets (MSDSs) with safety data sheets (SDSs). Although there are similarities between the two types of sheets, SDSs contain different information in a new format. Until May 31, 2017, suppliers may comply with either the MSDS requirements of WHMIS 1988 or the SDS requirements of WHMIS 2015. But after that date, manufacturers and importers must comply with the WHMIS 2015 SDS requirements. Here’s an overview of these requirements.

BASIC REQUIREMENTS

The WHMIS 2015 requirements for SDSs are contained in Part 4 of the HPR, while Schedule 1 lays out the SDS format and the content required under each of the 16 headings. Note that although headings 12-15 are included in a Canadian SDS to preserve the standard 16-heading format, the content to be provided under each heading is optional.

SDSs must be in both English and French. This information may appear either on a single bilingual SDS or on two separate unilingual documents that constitute one bilingual SDS.

WHMIS 1988 required MSDSs to be updated every three years. But under WHMIS 2015, SDSs must be updated to include significant new information—that is, information that changes the classification of the hazardous product or ways to protect against the hazards presented by the product—within 90 days of such information becoming available. In the interim 90-day period, when the hazardous product is sold, that information must be communicated, in writing, to any purchaser of it.

The chart below, which is based on one created by Health Canada, summarizes the SDS requirements under WHMIS 2015.

Section

Heading

Requirements
(Specific Information that Must Be Included)

1. Identification a. Product identifier;
b. Other means of identification;
c. Recommended use and restrictions on use;
d. Initial supplier identifier; and
e. Emergency telephone number and any restrictions on the use of that number, if applicable.
2. Hazard Identification a. Classification of the hazardous product;
b. The symbol, signal word, hazard statement and precautionary statement, for each of the applicable classes . If the required information element is a symbol, either the name of the symbol or the symbol itself may be used; and
c. Other hazards known to the supplier with respect to the hazardous product.
3. Composition/ Information on Ingredients If the hazardous product is a material or substance:
a. Chemical name;
b. Common name and synonyms;
c. CAS registry number and any unique identifiers; and
d. The chemical name of the impurities, stabilizing solvents and stabilizing additives that are known to the supplier, that individually are classified in any category or subcategory of a health hazard class, and that contribute to the classification of the material or substance.
If the hazardous product is a mixture:
a. Chemical name;
b. Common name and synonyms;
c. CAS registry number and any unique identifiers; and
d. Concentration of each material or substance in the mixture that, individually, is classified in a health hazard class and is present above the concentration limit for that class or, if not above the concentration limit, is present in the mixture at a concentration that results in the mixture being classified in any health hazard class.
4. First-aid Measures a. Description of necessary first-aid measures, subdivided according to the different routes of exposure (inhalation, ingestion, skin and eye contact);
b. The most important symptoms and effects, whether acute or delayed; and
c. An indication of immediate medical attention and special treatment needed, if necessary.
5. Fire-fighting Measures a. Suitable and unsuitable extinguishing media;
b. Specific hazards arising from the hazardous product, such as the nature of any hazardous combustion products; and
c. Special protective equipment and precautions for fire-fighters.
6. Accidental Release Measures a. Personal precautions, PPE and emergency procedures; and
b. Methods and materials for containment and cleaning up.
7. Handling and Storage a. Precautions for safe handling; andb. Conditions for safe storage, including any incompatibilities.
8. Exposure  Controls/ Personal
Protection
a. Control parameters, including occupational exposure limit values or biological limit values and the source of those values;
b. Appropriate engineering controls; and
c. Individual protection measures, such as PPE.
9. Physical and Chemical Properties a. Appearance, such as physical state and colour;
b. Odour;
c. Odour threshold;
d. pH;
e. Melting and freezing points;
f. Initial boiling point and boiling range;
g. Flash point;
h. Evaporation rate;
i. Flammability, in the case of solids and gases;
j. Upper and lower flammability or explosive limits;
k. Vapour pressure;
l. Vapour density;
m. Relative density;
n. Solubility;
o. Partition coefficient — n-octanol/water;
p. Auto-ignition temperature;
q. Decomposition temperature; and
r. Viscosity.
10. Stability and Reactivity a. Reactivity;
b. Chemical stability;
c. Possibility of hazardous reactions;
d. Conditions to avoid, including static discharge, shock or vibration;
e. Incompatible materials; and
f. Hazardous decomposition products.
11. Toxicological Information Concise but complete description of the various toxic health effects and the data used to identify those effects, including:
a. Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact);
b. Symptoms related to the physical, chemical and toxicological characteristics;
c. Delayed and immediate effects, and chronic effects from short-term and long-term exposure; and
d. Numerical measures of toxicity, including Acute Toxicity Estimates (ATEs).
12. Ecological Information Although the heading of this section is required to preserve the 16-heading format, content within this section is optional. Such content consists of:
a. Ecotoxicity (aquatic and terrestrial, if available);
b. Persistence and degradability;
c. Bioaccumulative potential;
d. Mobility in soil; and
e. Other adverse effects.
13. Disposal Considerations Although the heading of this section is required to preserve the 16-heading format, content within this section is optional and consists of information on safe handling for disposal and methods of disposal, including any contaminated packaging.
14. Transport Information Although the heading of this section is required to preserve the 16-heading format, content within this section is optional. Such content consists of:
a. UN number;
b. to d. United Nations proper shipping name,  transport hazard class, and packing group, as provided for in the UN Model Regulations;
e. Environmental hazards according to the International Maritime Dangerous Goods Code and the UN Model Regulations;
f. transport in bulk (according to Annex II of the International Convention for the Prevention of Pollution From Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78), and the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk); and
g. Special precautions in connection with transport or conveyance either within or outside the premises.
15. Regulatory Information Although the heading of this section is required to preserve the 16-heading format, content within this section is optional. Such content consists of safety, health and environmental regulations, made within or outside Canada, specific to the product in question.
16. Other Information Date of the latest revision of the SDS.