OSHA and Health Canada Issue Joint Guidance Documents
Occupational Safety and Health Administration (OSHA) and Health Canada have issued three new joint guidance documents to support implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). They’ve published the documents through the Regulatory Cooperation Council (RCC), which exists to assist companies who may need to manage regulatory requirements from both countries.
This guidance has been a long time coming – in fact, we previously blogged about plans for these new documents over two years ago. Let’s take a look at each of these documents and the ways they can help your business improve compliance with US and Canadian hazard communication requirements.
Comparison of Regulatory Processes
This new guidance provides a side-by-side comparison chart of the regulatory processes in Canada and the United States for hazardous products in the workplace.
The chart indicates the authorities in each country responsible for hazard communication regulations at the federal and the state or provincial levels, and how the different levels of government authorities interact. For example, it discusses the relationship between State OSHA Plans and federal OSHA in the US, and the alignment between the Workplace Hazardous Materials Information System (WHMIS) with the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR) in Canada. The documents also describe the requirements for suppliers, employers and workers under hazard communication regulations in Canada and the United States.
This new guidance document is available here.
Label Comparison for Shipped Containers
This new chart compares requirements for shipped labels under OSHA’s HazCom 2012 standard and with Canada’s Hazardous Product Regulations (HPR), and will be particularly useful for chemical manufacturers and suppliers who ship chemical products to both countries.
Among the most significant topics covered in the comparison chart are language, pictograms, hazard statement, precautionary statement and supplier identification requirements, and discussion of what types of supplemental information is allowed.
You can download the guidance document here.
Guidance on Hazards Not Otherwise Classified
The RCC first recognized the need for additional guidance regarding shipped labels for Hazards Not Otherwise Classified (HNOC), Physical Hazards Not Otherwise Classified (PHNOC), and Health Hazards Not Otherwise Classified (HHNOC) in its 2016-2017 Work Plan. The complicating issue for chemical manufacturers of products with these hazard classifications is that HazCom 2012 does not require label elements for HNOCs, whereas under the HPR, label elements are required PHNOCs and HHNOCs.
In the new guidance document, Health Canada and OSHA agree that the exclamation mark pictogram is appropriate for the HNOC, HHNOC, and PHNOC classifications. OSHA will permit the use of the exclamation mark pictogram for HNOCs if the words “Hazard Not Otherwise Classified” or “HNOC” appear below the pictogram. Canada does not require the additional information below the pictogram but will allow it to be present to facilitate consistency with US requirements.
The guidance document also clarifies that the exclamation mark pictogram may appear only once on the label, so if it already appears as a required pictogram, it may not make a second appearance as supplemental information for the HNOC.
Read the full guidance document here.
Let VelocityEHS Help!
As always, compliance with regulatory requirements for hazard communication starts with having all of your chemical hazard information accessible and actionable. This is especially true for businesses that must comply with regulations in both the US and Canada. Consider the benefits of modern EHS software to give you better visibility and control over your most important chemical information.
Our award-winning MSDSonline chemical management solutions can help you ensure that your business is aligned with Health Canada’s WHMIS 2015 regulation and OSHA’s HazCom 2012 regulation. Whether you need a way to more efficiently manage and provide employees with access to updated SDSs; generate secondary workplace container labels; assign, administer and document employee hazardous chemical safety training, or are in need for regulatory consulting guidance, we can help.
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