What is WHMIS?
WHMIS stands for Workplace Hazardous Materials Information System and is Canada’s national hazard communication standard. It outlines the obligations of each party in the chemical supply chain – from chemical suppliers, importers, and distributors who traffic in controlled products to the employers and workers who use them. WHMIS is based upon the idea that workers have the right to know about the hazards of the materials they work with and steps they can take to protect themselves.
On February 11, 2015 the Hazardous Products Regulations (HPR) was published in Canada Gazette II establishing the adoption of GHS through the revision of WHMIS. Additionally, a timeline was published setting out the compliance deadlines for suppliers and employers. (See GHS & WHMIS tab below.) This is the most significant change to Canada's national hazard communication standards since 1988. The new standard, which is being called WHMIS 2015, intentionally stays very close to OSHA's adoption of GHS in the United States, with a few notable exceptions. (Learn more about MSDSonline's WHMIS 2015 Training)
Health Canada estimates that 1 in 4 Canadian workers are exposed to controlled products on the job and that employee exposure to hazardous chemicals costs the economy more than $600 million annually. Health Canada further believes that aligning with the GHS standard will save $195.5 million over the next 20 years.
In 1988, to ensure worker access to adequate hazard information about chemicals in use at their work sites, an impressive coordination of federal, provincial and territorial legislation led to the implementation of a national hazard communication standard called WHMIS.
The three major tenets of WHMIS are:
- Labeling of WHMIS controlled products
- Provision of material safety data sheets (MSDSs)
- Worker education and training programs
Complicating WHMIS compliance are the rigorous provisions around MSDS management and workplace labeling. For example, among other WHMIS related responsibilities, employers must ensure MSDSs are updated every three years and that workplace containers (or secondary containers) of controlled products in the workplace are properly labeled.
Non-Compliance is Costly
WHMIS violations can result in fines of up to $1,000,000 and two years' imprisonment. Similar fines and imprisonment terms can be handed out for provincial violations and can lead to seizure of products and work site shut downs.
Health Canada estimates that several million chemicals are available to the Canadian market and that more than 3 million Canadian workers are exposed to chemicals on the job annually.
WHMIS is enforced by the Labour Branch of Human Resources Development Canada for federal workplaces and by the provincial or territorial agencies responsible for occupational health and safety for most other workplaces.
WHMIS Labels and MSDSs
When controlled products arrive in the workplace, they must be marked by supplier labels and accompanied by MSDSs. These labels and MSDSs must be presented in both English and French.
Under WHMIS, there are seven label categories required on most labels. (WHMIS does make allowance for the reduction of the number categories for containers of certain sizes and use.) The seven categories are:
- Product Identifier
- Supplier Identifier
- Reference to the MSDS
- Hazard Symbols
- Risk Phrases
- Precautionary Measures
- First Aid Measures
On WHMIS supplier labels – the letters, numbers and borders must contrast with other marking on the container. Additionally, employers are responsible for making sure no controlled products are used without proper labels. To that end, employers must use workplace labels when contents are transferred to new containers. Workplace labels must have at least 3 categories:
- Product Identifier
- Safe handling information
- MSDS Reference
MSDSs are integral to WHMIS and worker protection. For that reason, suppliers must provide MSDSs to customers on or before the time of sale of controlled substances. Employers must then make MSDSs available to workers in the workplace in such a way that they are easily accessible and where workers can study the information.
There are nine MSDS categories (under four sections) required by WHMIS. No category can be blank (for instance, not available or not applicable must be designated by something other than N/A). The nine categories are as follows:
- Identification and Recognition
- Product Information
- Hazardous Ingredients
- Physical data
- Risk Evaluation
- Fire and Explosion Hazard
- Reactivity data
- Toxicological data
- Preventive Measures
- Preventive Measures
- First Aid
- First Aid Measures
- Preparation Information
WHMIS To-Do List
Suppliers, employers and workers all have specified responsibilities in the Hazardous Products Act.
Suppliers, those who sell or import controlled products, must label products or containers, and provide material safety data sheets (MSDSs) to their customers. Labels must clearly identify the contents of the hazardous material, and the MSDS must explain those hazards.
Employers are required to establish education and training programs for workers exposed to hazardous products in the workplace and make sure that controlled products are labeled and MSDSs are present and readily available to workers.
Workers are required to participate in the training programs and to work safely with hazardous materials. They should inform employers when labels or MSDSs are missing, out of date, or otherwise compromised.
8 Key steps to implementing WHMIS in workplace
- Assign Responsibility – One Person Should be Designated as the Hazardous Materials Coordinator
- Inventory All Hazardous Products – Determine if the Products you have are Controlled or not and what Quantities they are Present
- Ensure Labeling and MSDS Requirements are Fulfilled
- Determine Hazards of Controlled Products
- Establish Workplace Controls
- Establish Emergency Procedures
- Provide Worker Education and Training
- Review and Upgrade
GHS and WHMIS
As the Canadian government releases more information about the transition to a GHS-aligned model, safety professionals in Canada would do well to familiarize themselves with the new GHS implementation schedule.
GHS stands for the Globally Harmonized System of Classification and Labelling and is a global approach to classifying hazardous chemicals and communicating their hazards developed by the United Nations and is being adapted in over 65 countries.
In February of 2015, Health Canada announced the transition for manufacturers, importers, distributors, and employers from the pre-GHS Controlled Products Regulations (CPR) standard to the GHS-aligned Hazardous Products Regulations (HPR) standard would proceed according to the following schedule:
|Manufacturers and Importers||Distributors||Employers|
From coming into force to June 1, 2017
|Use CPR or HPR requirements||Use CPR or HPR requirements||Use CPR or HPR requirements|
From June 1, 2017, to June 1, 2018
|Use HPR requirements||Use CPR or HPR requirements||Use CPR or HPR requirements|
From June 1, 2018, to December 1, 2018
|Use HPR requirements||Use HPR requirements||Use CPR or HPR requirements|
December 1, 2018
|Use HPR requirements||Use HPR requirements||Use HPR requirements|
However, there will still be differences between the U.S. and Canadian versions—particularly in areas relating to exemptions, hazard categories, and labeling requirements.In its announcement of the transition, the Canadian government emphasized that it intends to make its adoption of GHS comport very closely with OSHA’s GHS adoption in the United States.
Tabulation and analysis of these differences is ongoing. You can find out more (and check back for regular updates) on the MSDSonline EH&S Blog.