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Last Call for WHMIS 2015: The 10 Things OHS Directors Must Know to Comply with WHMIS Training Rules

It’s last call for WHMIS compliance. On Dec. 1, 2018, employers that use, handle, store or dispose of hazardous products in the workplace must be done revising their WHMIS programs to comply with the new WHMIS 2015/GHS rules. The first order of business: Ensuring that workers have the necessary training. Here are the 10 things OHS directors need to know to achieve that objective.

  1. Which Workers Need WHMIS Training

There’s a common misconception that WHMIS training must be provided to all workers. The truth is that workers need WHMIS training only if they are or may be exposed to a hazardous product at work, i.e., they:

  • Work with a hazardous product(s);
  • Work near a hazardous product(s);
  • Are involved in the manufacture of a hazardous product.
  1. When Initial Training Is Required

Training must be provided before the worker is exposed. That may be a new worker’s first day of work or a current worker’s 1,000th day if he’s assigned to a new position or location involving exposure, e.g., an office maintenance worker is assigned to perform cleaning duties in a chemical storage area.

  1. The Difference between WHMIS & GHS Training

The GHS changes that were adopted in 2015 and take effect on Dec. 1 affect essential elements of the WHMIS program covered in WHMIS training, including supplier and workplace labels and Material Safety Data Sheets (MSDS) (which are now Safety Data Sheets (SDS)). Accordingly, all workers exposed to hazardous products (which used to be called “controlled products”) and who’ve presumably already received WHMIS training will need training in the GHS changes by the Dec. 1 deadline.

  1. How to Verify Training Effectiveness

Simply delivering WHMIS (and GHS) training isn’t enough. Before exposing them to a hazardous product, you must also verify that workers understand their training and are capable of applying it to protect their health and safety. Methods of verification include making workers pass a written test and/or demonstrate what they learned. Periodic evaluation of workers’ knowledge via written tests, practical demonstrations and other “suitable means” is also a specific regulatory requirement in BC, New Brunswick, Newfoundland, Prince Edward Island and Saskatchewan and a recommended best practice in all other jurisdictions.

  1. When New or Refresher WHMIS Training Is Required

The phrase “annual WHMIS training” is a misnomer. OHS rules don’t say that says that WHMIS training is required every year. In fact, WHMIS training has no pre-determined shelf life. It lasts as long as the training remains timely and reflective of current conditions and hazards. New training is required only when and if:

  • Work conditions change in a way that alters the exposure risks covered in the previous training;
  • New and significant hazard information about the hazardous product becomes available after training takes place;
  • Periodic evaluations indicate that workers don’t have adequate knowledge to apply their training; and/or
  • There are other indications that the previous training isn’t effective and needs refreshing.
  1. The Difference between Annual WHMIS Training & Annual WHMIS Review

There is one thing WHMIS laws say you must do at least once a year: Review your entire WHMIS program, including worker training and education. During this review, you must determine whether the most recent WHMIS training workers received is appropriate and suitable to current conditions or, conversely, whether work conditions, new information or other changes make refresher or retraining necessary.

  1. Who Must Be Involved in Annual WHMIS Review

Annual WHMIS review must be done in consultation with the workplace joint health and safety committee (JHSC) or health and safety representative.  Although not specifically defined in OHS regulations, government guidance from Alberta, BC and other jurisdictions clarify that “consultation” means giving the JHSC or representative a chance to review and comment on the effectiveness, content, structure and means of delivering WHMIS training.

Other Issues to Cover During Annual WHMIS Review

In addition to training and education, annual WHMIS review should include verification that:

[  ] The company’s procedures for safe use, storage, handling and disposal of hazardous products are timely and effective
[  ] Effective spill and emergency response procedures are in place
[  ] There’s an up-to-date list of all hazardous products used or stored in the workplace
[  ] There’s an up-to-date SDS for each of these products
[  ]  Chemical containers have proper and legible WHMIS labels

 

  1. The Difference between WHMIS Training and Hazard Information

OHS rules require employers to ensure workers receive both WHMIS training and hazard information about the specific hazardous product(s) to which they’re exposed. OHS directors can get into trouble if they confuse these things.

  1. What WHMIS Training Covers

WHMIS training is general in scope. Its aim is to teach workers how the WHMIS system works and how to use it to ensure their health and safety, as well as about the general policies and procedures in place to protect them from exposure to hazardous products and substances. Required elements:

  • Information that must be on an SDS and the significance of that information;
  • How to access the workplace SDS binder or system;
  • Information that must be on a WHMIS supplier or workplace label and the significance of that information;
  • Placards or other alternative methods used to communicate required safety information about hazardous products;
  • Procedures for safe storage, handling, use and disposal (and, if applicable, manufacture) of hazardous products; and
  • Procedures for hazardous product emergencies and exposure to so-called fugitive emissions.
  1. What Hazard Information Covers

“Hazard information” means information about the safe use, storage, handling and disposal of a particular hazardous product to which the worker is exposed, including information about its health and physical hazards and how to deal with emergencies involving the product. The source of that information is the company that supplies the hazardous product and you’ll need to let workers know if and when the supplier provides you new or updated hazard information about the product.