The federal government recently published the final Hazardous Products Regulations (HPR), which implement the GHS in Canada. Among other things, the new WHMIS, called “WHMIS 2015,” contains new requirements for supplier labels. Suppliers may comply with the label requirements of either “old” WHMIS (now referred to as WHMIS 1988) or WHMIS 2015 until May 31, 2017. After that date, manufacturers and importers must comply with the WHMIS 2015 label requirements. Here’s an overview of the new supplier label requirements.
Most of the label requirements are contained in Part 3 of the HPR. Suppliers—defined as persons who, in the course of business, sell or import a hazardous product—must prepare labels and provide them to purchasers of hazardous products intended for use in a workplace. Labels must be accurate at the time of each sale or importation of the hazardous product. They must be updated within 180 days of when new significant information about the product becomes available. And until the label is updated, the new information and date upon which it became available must be sent in writing by the product’s seller to the person who acquires it. Supplier labels must be durable and legible without the aid of any devices other than corrective lenses.
In addition, the HPR spells out:
What information or elements must be included on a supplier label. See the chart below for a comparison of the required label elements under WHMIS 2015 and WHMIS 1988. Although the basic elements of the two labels are similar, some of the specifics are different. For example, although both require the use of pictograms, WHMIS 2015 adopts the GHS pictogram format of a black symbol on a white background with a red frame in the shape of a square set on a point. Note that two elements of supplier labels from WHMIS 1988 have been dropped:
- The hatched border around the label content; and
- A statement to the effect that a material safety data sheet (now referred to as safety data sheets or SDS) is available.
How the label should appear. For example, the pictogram, signal word and hazard statement must be grouped together on the label.
What languages are used on the label. The informational elements on a supplier label should be in both English and French. The elements may appear either on a single bilingual label or in a group of information elements in two unilingual parts that constitute one bilingual label.
Exceptions to the label requirements. For example, bulk shipments of a hazardous product aren’t subject to the label requirements.
|Comparison of General Supplier Labels|
|WHMIS 1988||WHMIS 2015|
|Product identifier||Product identifier|
|Supplier identifier||Supplier identifier|
|Risk Phrases||Hazard statement|
|Precautionary measures||Any applicable precautionary statements, including:
|First aid statement||Incorporated in the precautionary statements|
|N/A||Where applicable, supplemental label elements based on the classification of the workplace hazardous chemical|