Assume that GHS/WHMIS 2015 is now in full effect. While reviewing your SDS binder, you come upon the following 4 SDSs:
- SDS-A is 7-years-old but all the listed information remains accurate and up to date;
- SDS-B is 4-years-old and the chemical classification listed is out of date;
- SDS-C is less than 1-year-old and lists out of date handling and usage information;
- SDS-D is brand new and lists timely and accurate information but follows the old MSDS format.
Which SDS does NOT have to updated?
SDS-A is still valid; but the other 3 are out of date and need to be revised or replaced.
The point of this scenario is to illustrate how the new GHS/WHMIS 2015 rules for updating an MSDS—now called SDS—work. Under the old rule, an MSDS had to be updated in response to significant changes in information about the product and at least once every 3 years. Under the new rules, an SDS need only be revised in response to “significant new data” affecting the product’s classification or safe handling and usage. In other words, the regular triennial update requirement has been eliminated. And because the information in SDS-A is still timely, the document itself is also still good even though it’s the oldest one in the batch.
WHY WRONG ANSWERS ARE WRONG
B is wrong. SDS-B does need updating, not because it’s over 3-years-old but because its product classification is out of date.
C is wrong because changes in safe handling and usage information is “significant new data” requiring an update.
D is wrong because effective December 1, 2015, the old MSDS format is invalid and all SDSs must follow the new WHMIS 2015 SDS format.