WHAT YOU NEED TO KNOW ABOUT GLOBAL HARMONIZED SYSTEM (GHS) OF CLASSIFICATION AND LABELLING OF CHEMICALS: MSDS and SDS – Understanding the differences

As Global Harmonized System (GHS) of Classification and Labelling of Chemicals are being implemented, it is important to learn the differences between WHMIS 1988 and WHMIS 2015 which includes GHS; its impact to you in terms of safety and handling usage of chemical solutions.

8/2/2016

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WHAT YOU NEED TO KNOW ABOUT GLOBAL HARMONIZED SYSTEM (GHS) OF CLASSIFICATION AND LABELLING OF CHEMICALS:

1. GHS BACKGROUND INFORMATION: • An international team of hazard communication experts of the United Nations Economic Commission for Europe

(UNECE) developed GHS. • The first edition was adopted in 2002. • 2015 (Revision 6). Regularly revised and updated to reflect national, regional and international experiences and

laws. For example: Before GHS, a product with an Oral RAT LD50 at 257 mg/kg could have been classified as: Toxic in Canada, US, Japan and Korea Harmful in European Union, Australia, Malaysia and Thailand Moderately Toxic in China Hazardous in New Zealand Non-toxic in India

2. ABOUT GHS: GOAL: To have same set of rules for classifying hazards, and the same format and content for labels and safety data sheets (SDS), to be adopted and used around the world.

TRUTH: Not uniform across all regions as they rely on different revisions of GHS. Local competent authorities also may amend the decision logic to emphasize their interpretation of the GHS model regulations.

3. WHMIS BACKGROUND INFORMATION:

• WHMIS (or SIMDUT) stands for Workplace Hazardous Materials Information System • It is a LAW since 1988 (For more information, see Section 7 for differences between WHMIS 1988 and WHMIS 2015) • It applies to : Suppliers, Employers, Workers

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4. WHMIS 2015 - ROLES AND RESPONSIBILITY: SUPPLIER’S DUTIES: EMPLOYERS’ DUTIES: WORKER’S DUTIES: • Must ensure the appropriate

classification of hazardous products.

• Must label the hazardous product or container and they must provide a safety data sheet (SDS) to their customers.

• The purpose of the label is to clearly identify the hazardous ingredients, the supplier, the hazards and precautionary measures.

• The SDS provides additional information about the product.

• Educate and train workers on the hazards and safe use of the products

• Ensure that hazardous products are properly labelled.

• Prepare and provide up-to-date: Workplace labels and SDSs

• Make available all Personal Protective Equipment (PPE) to the employees

• Participate in WHMIS education and training programs

• Take necessary precautions to protect themselves and co-workers by following safety and handling usage of products.

• Use the appropriate Personal Protective Equipment (PPE)

5. EXEMPTION to WHMIS 2015: Not all hazardous products fall under the WHMIS regulation. The exemptions under WHMIS are:

• Explosives as defined in the Explosives Act. • Cosmetic, device, drug or food as defined in the Food and Drugs Act. • Pest control products as defined in the Pest Control Products Act. • Consumer products as defined in the Canada Consumer Product Safety Act. • Wood or products made of wood. • Etc.

Many of these products are covered under other legislation. Note that while a product may be exempt from the requirement to have a WHMIS label and SDS, employers must still provide education and training on health effects, safe use, and storage. 6. GHS IN CANADA – WHMIS 1988 VS WHMIS 2015

• Canada has included GHS into the WHMIS 2015 Regulation • The Hazardous Products Regulations (WHMIS 2015) now replace The Controlled Products Regulations (WHMIS

1988). New classification rules and hazard classes • A standardized format for Safety Data Sheet (formerly MSDS) that will now contain 16 sections instead of 9. • New hazard pictograms • New label requirements, including warnings

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• At the outset of the transition period, the supplier must fully comply with either the repealed Controlled Products Regulations (WHMIS 1988) or the HPR (WHMIS 2015) for a specific controlled or hazardous product. The classification, label and (material) SDS must comply fully with the specific regulation chosen by the supplier, and not be a combination of the two. In the United States, it must comply with CFR (Code of Federal Regulations ). Please refer to OSHA for US regulations for labels and SDS.

7. GHS PICTOGRAMS – DIFFERENCES WHMIS 1988:

WHMIS 2015:

GHS09 was not adopted in WHMIS 2015 but allowed. *Red diamond border is obligatory*

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8. LABELS - DIFFERENCES: SUPPLIER LABEL:

WHMIS 1988: WHMIS 2015:

9. MSDS AND SDS DIFFERENCES: WHMIS 1988 - MSDS (9 sections) WHMIS 2015 - SDS (16 sections) 1. Product information 2. Information on the preparation of the MSDS 3. Hazardous ingredients 4. Physical data 5. Fire and explosion hazards 6. Reactivity data 7. Toxicological properties 8. Preventive measures 9. First aid measures

1. Identification 2. Hazard identification 3. Composition / information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release 7. Handling and storage 8. Exposure controls / Personal protection 9. Physical and chemical proprieties 10. Stability and reactivity 11. Toxicological information 12. Ecological information* 13. Disposal considerations* 14. Transport information* 15. Regulatory information* 16. Other information

* GHS SDS: Sections 12 to 15 require the headings to be present, but under Canadian regulations, the supplier has the option to not provide information in these sections.

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10. UNDERSTANDING HAZARD STATEMENTS ON SDS AND LABELS Every level of hazard (category) within each hazard class has one single hazard statement assigned to it. It is important to understand the ratings and differentiate them on the SDS and the labels. The Hazard Material Identification System (HMIS) on the label is based on the National Fire Protection Association (NFPA). The NEW GHS Category is also a numberic system, but it is reversed from that of the NFPA system.

Sample Label:

SDS (section 2):

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11. GHS ALIGNMENT TIMELINE FOR TRANSITION IN CANADA:

The following explanation refers to the transition provisions for WHMIS 2015 which stem from the Hazardous Products Act (HPA) and its associated regulations, the Controlled Products Regulations (CPR) and Hazardous Products Regulations (HPR). The FPT OSH (Federal, Provincial and Territories Occupational Safety and Health) are the different legislations involved in the process because even if the regulation is approved in Canada, some responsibilities are provincial or territorial.

For more information related to transition to employer requirements of WHMIS 2015 in specific jurisdictions, please direct enquiries to the federal, provincial, territorial (FPT) occupational health and safety (OSH) regulatory agencies, found in WHMIS Contacts. TRANSITION PHASES:

12. IMPORTANT DETAILS CONCERNING SDS: • If the label of a product was updated to GHS, (by law) the SDS of the product must only be used. • It is not permitted to give a MSDS if you have a new GHS label and vice versa - it is not permitted to give a SDS if

your product still bares old labels. • Due to the fact that GHS has reclassified all chemicals to make it harmonized around the world, there will be

differences between the warnings and hazards in the MSDS and SDS. Sometimes the classification might be more severe and sometimes it might be less severe.

• Though a product may have green certifications from UL ECOLOGO and Green Seal and is biodegradable, it does not mean that it does not contain any toxicity to aquatic or to the environment. A manufacturer can purchase the greenest raw material available but it may still contain some toxicity that meets the threshold that a green certification may allow. Green certification by ECOLOGO or Green Seal independently verifies that a product has met each required attribute, from a very strict, comprehensive, and multi-stakeholder involvement standard created for a category of products, and therefore is proven safer than comparative products. However, certification does not mean “safe”, but rather “safer”.

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• During the GHS transition period, there may still be some adjustments to the classification of products for everyone worldwide; therefore it is the manufacturer’s responsibility to verify that the classifications are up to date.

• Expiration date of MSDS is 3 years after it has been issued. For example: Issue date: January 1, 2014, expiration date will be January 1, 2017. However, it is important to note that expiration date of SDS will only need to be updated when the formula of the product has been changed. With the new GHS, the SDS has no expiration date. Manufacturer just needs to indicate when the SDS has last been updated.

• A manufacturer may issue an MSDS with 16 sections that looks similar to an SDS. To ensure that you have an updated SDS (WHMIS 2015) and not a MSDS (WHMIS 1988), it is important to verify the following:

1. The SDS has 16 sections. 2. The ‘Hazardous Products Regulations (HPR)’ is clearly indicated; then it is following WHMIS 2015. If it

indicates ‘The Controlled Products Regulations (CPR)’; then it is following WHMIS 1988. This can be found either in Section 2 or Section 15 of the SDS.

3. In the SDS, the pictograms are in color with the red diamond border on them and has the classifications GHS01 to GHS09 (as indicated in this document, section 7: GHS PICTOGRAMS-DIFFERENCES)

AVMOR’S POSITION ON SDS AND GHS LABELLING:

As a manufacturer, the SDS is provided to protect the long term health, safety and well-being of the user, all people using or visiting the buildings being cleaned, and the planet. Avmor recognizes that the users may be in contact with cleaning chemicals for several hours per day, each day of the week, for a number of years in their work life. At Avmor, we want to be transparent; to ensure that we provide our customers with the necessary information to make the right decisions; to provide instructions for proper handling and safe use of the product and thereby allow for risk mitigation. It is recommended to follow the instructions provided on the SDS. The information on the SDS is based on present knowledge. However, this shall not constitute a guarantee for any specific product features and shall not establish a legally valid contractual relationship. Actual conditions of use and handling are beyond Avmor's control. User is responsible to evaluate all available information when using a product for any particular use and to comply with all Federal, State, Provincial and Local laws and regulations. The health, safety and well being of all people using our products, and those using or visiting the facilities being cleaned with our products is a priority to Avmor. It is important that all take the time to educate themselves to ensure that all manufacturers follow the GHS guidelines and that the information and data that the manufacturers are providing are accurate and that you are accurately comparing alternatives.