INTRODUCTION: HOW TO USE THIS TOOL
The Material Safety Data Sheet (MSDS) and WHMIS supplier label are being replaced. By December 1, 2018, all hazardous products (aka, what were once called “controlled products”) will require a new GHS Safety Data Sheet and supplier label. Starting Sept. 1, your suppliers should provide you compliant SDS and supplier labels for their products. But if they don’t, you’ll need to take the bull by the horns and request them to send the materials you need. You’ll be able to get by without an SDS and/or supplier label for 3 to 6 months provided that you can document the reasonable efforts you make to obtain the materials from your supplier. A written request (or thorough documentation of a verbal or oral request) will be a crucial piece of documentation. Here’s a Model Written Request you can adapt. Click here for a parallel form you can use to document requests for a by telephone or verbally.
MODEL LETTER TO SUPPLIER REQUESTING GHS-COMPLIANT SDS AND/OR SUPPLIER LABEL
[Your company letterhead]
October 15, 2018
Via Regular Mail
Cam Michael, Distribution Manager
Hazardous Products Chemical Suppliers (HPCS)
123 Toxic Drive
Any Town, Province 66666
Re: Request for Safety Data Sheet/GHS Supplier Label
On September 15, our organization, ABC Company, received a shipment from you containing 36 barrels of Chloroform, Technical Alcohol Free, a chemical designated as a hazardous product under the federal Hazardous Product Act and associated regulations. With the shipment, you included a Material Safety Data Sheet (MSDS) listing safety information about the product.
While we appreciate the service, we are also concerned that the MSDS you provided lists the information and follows the format required for an MSDS under the previous WHMIS rules. As you know, effective September 1, 2018, suppliers are required to furnish not an MSDS but a new GHS-compliant Safety Data Sheet, or SDS, to their customers.
Unfortunately, the same problem arose with respect to the WHMIS supplier label. The label you provided us is designed to comply with the old WHMIS supplier label requirements being phased out and not the new GHS supplier label rules.
Having done business with HCPS for so many years, we are sure that there is a simple and reasonable explanation for the mistake. Nevertheless, we do need you to correct the problem and send us the GHS-compliant SDS and supplier label for the shipment as soon as possible so that we can have the required information on hand by December 1, 2018 when our own GHS compliance deadline as an employer falls.
Thank you for your prompt attention to this matter.
Very truly yours,